CORNERSTONE WEALTH MANAGEMENT, LLC

Item 1: Cover Page Part 2A of Form ADV: Firm Brochure April 2025 7417 Mexico Road, Suite 104 St. Peters, MO 63376 Firm Contact: Thomas Gooden Chief Compliance Officer This brochure provides information about the qualifications and business practices of Cornerstone Wealth Management, LLC and its DBAs If clients have any questions about the contents of this brochure, please contact us at (636) 397-6200 or thomas.gooden@lpl.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any State Securities Authority. Additional information about our firm is also available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD #164666. Please note that the use of the term “registered investment adviser” and description of our firm and/or our associates as “registered” does not imply a certain level of skill or training. Clients are encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise clients for more information on the qualifications of our firm and our employees.  Item 2: Material Changes Our firm is required to make clients aware of information that has changed since the last annual update to the Firm Brochure (“Brochure”) and that may be important to them. Clients can then determine whether to review the brochure in its entirety or to contact us with questions about the changes. Since the last annual amendment filed on 03/28/2024, the following material change(s) have been made: • We have updated Item 5 to disclose that our firm may charge an hourly fee of up to $400 for Financial Planning & Consulting services. The specific fee arrangement will be detailed in the signed agreement with our firm. Please see Item 5 for additional information. • We have updated Item 5 to disclose that our firm will manage certain client account(s) that are held at a custodian that is not directly accessible by our firm using Pontera Solutions, Inc. (“Pontera”)’s order management system. The advisory fee payable for any held away accounts will be deducted directly from another client account. If there are insufficient funds available in another client account or our firm believes that deducting the advisory fee from another client account would be prohibited by applicable law, we will invoice the client directly. Please see Item 5 for additional information. • Our firm has established an arrangement where we recommend Visible National Trust, a third-party provider specializing in special needs trust services, to clients who require such services. If a client elects to engage Visible National Trust, they will enter into a separate trust agreement directly with that entity. Our firm’s financial advisors will receive compensation for investment management services provided to clients who establish trust accounts with Visible National Trust. Our firm and its financial advisors therefore have a financial incentive to recommend Visible National Trust over other trust service providers. To mitigate this conflict, clients are encouraged to conduct independent due diligence and consider multiple trust providers before making a selection. Please see Item 14 for additional information. ADV Part 2A – Firm Brochure Page 2 Cornerstone Wealth Management, LLC  Item 3: Table of Contents Page(s): Section: Item 2: Material Changes ...................................................................................................................................................... 2 Item 3: Table of Contents ..................................................................................................................................................... 3 Item 4: Advisory Business.................................................................................................................................................... 4 Item 5: Fees & Compensation ............................................................................................................................................. 8 Item 6: Performance-Based Fees & Side-By-Side Management ......................................................................... 12 Item 7: Types of Clients & Account Requirements .................................................................................................. 12 Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ................................................................. 13 Item 9: Disciplinary Information..................................................................................................................................... 17 Item 10: Other Financial Industry Activities & Affiliations .................................................................................. 17 Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading ............. 17 Item 12: Brokerage Practices ........................................................................................................................................... 18 Item 13: Review of Accounts or Financial Plans ....................................................................................................... 22 Item 14: Client Referrals & Other Compensation ..................................................................................................... 22 Item 15: Custody .................................................................................................................................................................... 24 Item 16: Investment Discretion ....................................................................................................................................... 25 Item 17: Voting Client Securities ..................................................................................................................................... 25 Item 18: Financial Information ........................................................................................................................................ 25 ADV Part 2A – Firm Brochure Page 3 Cornerstone Wealth Management, LLC  Item 4: Advisory Business We specialize in the following types of services: asset management, financial planning and consulting, retirement consulting and management, and referrals to third party money managers. We are dedicated to providing individuals and other types of clients with a wide array of investment advisory services. Our firm is a limited liability company formed in the State of Missouri. Our firm has been in business as an investment adviser since 2005 and is owned as follows: Donald Aulbert – 1% David Kaplan – 1% Leslie Garrison – 1% Liyin Bao – 1% Thomas Gooden – 1% John Howard – 1% Khurram Naveed – 1% Gregory Shoemaker –31.85% Joseph Keifer – 31.85% Dean Millonas – 14.30% Patrick Lodes – 5% William Friebel – 4% Karen Torrence – 2% Chris Swenson – 2% John Wehmer – 2% Our firm also conducts business under the following names: Vine Wealth Management Milestone Investment Counsel Carlisle Mott Financial Stauros Financial, LLC Legends Financial Services Group, LLC Focus Wealth Management Rains Wealth Management Stockyard Wealth Management Triada Advisors Stone 8 Wealth Management, LLC Dixon Incorporated Bell & Associates Wealth Management Steamboat Financial Group GenFinity Wealth Management Lifetime Planning, Inc. Morse Wealth Management West Financial Services Advisory Services We Offer Asset Management We emphasize continuous and regular account supervision. As part of our asset management service, we generally create a portfolio, consisting of individual stocks or bonds, exchange traded funds (“ETFs”), exchange traded notes (“ETNs”), options, mutual funds and other public and private securities or investments. We also provide investment management services for plan participants’ 401(k)s including rollover options and the risks of moving assets out of 401(k) plans. The client’s individual investment strategy is tailored to their specific needs and may include some or all of the previously mentioned securities. Each portfolio will be initially designed to meet a particular investment goal, which we determine to be suitable to the client’s circumstances. This may also include insurance analysis, estate and tax planning strategies, industry education and financial planning, etc. Once the appropriate portfolio has been determined, we review the portfolio at least annually and if necessary, rebalance the portfolio based upon the client’s individual needs, stated goals and objectives. Each client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. ADV Part 2A – Firm Brochure Page 4 Cornerstone Wealth Management, LLC  Retirement Consulting and Management We provide retirement consulting management services on a one-time or ongoing basis. Generally, such services consist of assisting plan sponsors in establishing, monitoring and reviewing their participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising could include: investment options, plan structure and participant education. All retirement consulting and management services shall be in compliance with the applicable laws regulating retirement consulting services. This applies to client accounts that are pension or other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and we accept appointments to provide our services to such accounts, we acknowledge that we are a fiduciary within the meaning of Section 3(21) or 3(38) of ERISA (but only with respect to the provision of services described in our advisory agreement). Financial Planning and Consulting We provide a variety of financial planning and consulting services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of the client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: Investment Planning, Retirement Planning, Estate Planning, Charitable Planning, Education Planning, Cost Segregation Study, Corporate Structure, Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation, Business and Personal Financial Planning. Our written financial plans or financial consultations rendered to clients usually include general recommendations for a course of activity or specific actions to be taken by the clients. For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. It should also be noted that we refer clients to an accountant, attorney or other specialist, as necessary for non-advisory related services. For written financial planning engagements, we provide our clients with a written summary of their financial situation, observations, and recommendations. For financial consulting engagements, we usually do not provide our clients with a written summary of our observations and recommendations as the process is less formal than our planning service. Plans or consultations are typically completed within six months of the client signing a contract with us, assuming that all the information and documents we request from the client are provided to us promptly. Implementation of the recommendations will be at the discretion of the client. LPL Sponsored Advisory Programs When appropriate, we have the ability to provide advisory services through certain programs sponsored by LPL Financial, LLC (“LPL”). Below is a brief description of each LPL advisory program available to us. Annualized fees for participation in LPL advisory programs vary up to maximum of 3.00%. For more information regarding the LPL programs, including more information on the advisory services and fees that apply, the types of investments available in the programs and the potential conflicts of interest presented by the programs please see the LPL Financial Form ADV Part 2 or the applicable LPL program’s Wrap Fee Program Brochure and the applicable LPL Financial client agreement. ADV Part 2A – Firm Brochure Page 5 Cornerstone Wealth Management, LLC  Guided Wealth Portfolios Program (“GWP”) GWP offers clients the ability to participate in a centrally managed, algorithm-based investment program, which is made available to users and clients through a web-based, interactive account management portal (“Investor Portal”). Investment recommendations to buy and sell open-end mutual funds and exchange-traded funds are generated through proprietary, automated, computer algorithms (collectively, the “Algorithm”) of Xulu, Inc., doing business as FutureAdvisor (“FutureAdvisor”), based upon model portfolios constructed by LPL and selected for the account as described below (such model portfolio selected for the account, the “Model Portfolio”). Communications concerning GWP are intended to occur primarily through electronic means (including but not limited to, through email communications or through the Investor Portal), although our firm will be available to discuss investment strategies, objectives or the account in general in person or via telephone. A preview of the GWP Program (the “Educational Tool”) is provided for a period of up to 45 days to help users determine whether they would like to become advisory clients and receive ongoing financial advice from LPL, FutureAdvisor and our firm by enrolling in the advisory service (the “Managed Service”). The Educational Tool and Managed Service are described in more detail in the GWP Program Brochure. Users of the Educational Tool are not considered to be advisory clients of LPL, FutureAdvisor or our firm, do not enter into an advisory agreement with LPL, FutureAdvisor or our firm, do not receive ongoing investment advice or supervisions of their assets, and do not receive any trading services. A minimum account value of $5,000 is required to enroll in the Managed Service. Manager Access Select Program (“MAS”): MAS provides clients access to the investment advisory services of professional portfolio management firms for the individual management of client accounts. We will assist client in identifying a third party portfolio manager (Portfolio Manager) from a list of Portfolio Managers made available by LPL Financial. The Portfolio Manager manages client’s assets on a discretionary basis. We will provide initial and ongoing assistance regarding the Portfolio Manager selection process. A minimum account value of $100,000 is required for Manager Access Select, however, in certain instances, the minimum account size may be lower or higher. Optimum Market Portfolios Program (“OMP”) OMP offers clients the ability to participate in a professionally managed asset allocation program using Optimum Funds Class I shares. Under OMP, the client will authorize LPL Financial on a discretionary basis to purchase and sell Optimum Funds pursuant to investment objectives chosen by the client. We will assist the client in determining the suitability of OMP for the client and assist the client in setting an appropriate investment objective. Adviser will have discretion to select a mutual fund asset allocation portfolio designed by LPL consistent with the client’s investment objective. LPL Financial will have discretion to purchase and sell Optimum Funds pursuant to the portfolio selected for the client. LPL Financial will also have authority to rebalance the account. A minimum account value of $10,000 is required for OMP. Personal Wealth Portfolios Program (“PWP”) PWP offers clients an asset management account using asset allocation model portfolios designed by LPL Financial. We will have discretion for selecting the asset allocation model portfolio based on client’s investment objective. We will also have discretion for selecting third party money managers ADV Part 2A – Firm Brochure Page 6 Cornerstone Wealth Management, LLC  (PWP advisors) or mutual funds within each asset class of the model portfolio. LPL Financial will act as the overlay portfolio manager on all PWP accounts and will be authorized to purchase and sell on a discretionary basis mutual funds and equity and fixed income securities. A minimum account value of $250,000 is required for PWP. Model Wealth Portfolios Program (MWP) MWP offers clients a professionally managed mutual fund asset allocation program. We will obtain the necessary financial data from the client, assist the client in determining the suitability of the MWP program and assist the client in setting an appropriate investment objective. We initiate the steps necessary to open an MWP account and have discretion to select a model portfolio designed by LPL Financial’s Research Department consistent with the client’s stated investment objective. LPL Financial’s Research Department is responsible for selecting the mutual funds within a model portfolio and for making changes to the mutual funds selected. The client will authorize LPL Financial to act on a discretionary basis to purchase and sell mutual funds, including in certain circumstances exchange traded funds and to liquidate previously purchased securities. The client will also authorize LPL Financial to effect rebalancing for MWP accounts. The MWP program may make available model portfolios designed by strategists other than LPL’s Research Department. If such models are made available, we will have discretion to choose among the available models designed by LPL and outside strategists. A minimum account value of $25,000 is required for MWP. Tailoring of Advisory Services We offer individualized investment advice to clients utilizing the Asset Management service. Additionally, we offer general investment advice to clients utilizing Financial Planning and Consulting and Retirement Consulting and Management services. Each Asset Management client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account. Participation in Wrap Fee Programs We offer wrap fee programs as further described in Part 2A, Appendix 1 (the “Wrap Fee Program Brochure”) of our Brochure. Our wrap fee and non-wrap fee accounts are managed on an individualized basis according to the client’s investment objectives, financial goals, risk tolerance, etc. We do not manage wrap fee accounts in a different fashion than non-wrap fee accounts. As further described in our Wrap Fee Program Brochure, we receive a portion of the wrap fee for our services. Regulatory Assets Under Management Our firm managed $4,082,513,557 on a discretionary basis and $0 on a non-discretionary basis as of 12/31/2024. ADV Part 2A – Firm Brochure Page 7 Cornerstone Wealth Management, LLC  Item 5: Fees & Compensation We are required to describe our brokerage, custody, fees, and fund expenses so you will know how much you are charged and by whom for our advisory services provided to you. Actual fees paid by clients who engage our firm through an advisor who has joined Cornerstone Wealth Management may be different than published below as we allow advisors to grandfather their previously established advisory fee schedules with our firm. Asset Management Assets Under Management $0 to $499,999.99 $500,000 to $999,999.99 Over $1,000,000 Annual Percentage of Assets Charge Up to 2.4% Up to 1.9% Up to 1.4% For LPL Accounts: The fee to be assessed to each account will be detailed in the client’s signed advisory agreement, LPL Account Application, or LPL Tiered Fee Authorization form. Fees are billed on a pro-rata basis quarterly in advance based on the value of the account(s) on the last day of the previous quarter. Fees are negotiable and will be deducted from the account(s). Fees are adjusted for deposits and withdrawals made during the quarter. We bill on cash or cash equivalents unless otherwise indicated in writing. If accounts are opened during the quarter, the pro-rata advisory fees will be deducted during the next regularly scheduled billing cycle. Our firm does not offer direct invoicing. As part of the fee deduction process, clients understand the following: a) LPL as the client’s custodian sends statements at least quarterly, showing all disbursements for each account, including the amount of the advisory fees paid to our firm. b) Clients provide authorization permitting LPL to deduct these fees. c) LPL calculates the advisory fees for all fee schedules and deducts them from the client’s account. For Other Custodian Accounts: Fees to be assessed will be outlined in the advisory agreement to be signed by the client. Annualized fees are billed on a pro-rata basis quarterly in advance based on the value of the account(s) on the last day of the previous quarter. Fees are negotiable and will be deducted from client account(s). Fees are not adjusted for deposits and withdrawals made during the quarter. We bill on cash or cash equivalents unless otherwise indicated in writing. If accounts are opened during the quarter, the pro- rata advisory fees will be deducted during the next regularly scheduled billing cycle. Our firm does not offer direct invoicing. As part of the fee deduction process, clients understand the following: a) The client’s independent custodian sends statements at least quarterly showing the market values for each security included in the assets and all account disbursements, including the amount of the advisory fees paid to our firm. b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our firm will send an invoice directly to the custodian. ADV Part 2A – Firm Brochure Page 8 Cornerstone Wealth Management, LLC  c) If we send a copy of our invoice to the client, our invoice will include a disclosure urging the client to compare the information provided in our statement with those from the qualified custodian. In certain cases, our firm will manage client account(s) that are held at a custodian that is not directly accessible by our firm using Pontera Solutions, Inc. (“Pontera”)’s order management system. The advisory fee payable for any held away accounts will be deducted directly from another client account. If there are insufficient funds available in another client account or our firm believes that deducting the advisory fee from another client account would be prohibited by applicable law, we will invoice the client directly. Retirement Account Consulting and Management We charge on an hourly, flat fee, or a percentage of assets under management basis for our Retirement Account Consulting and Management services. The total estimated fee, as well as the ultimate fee that we charge you, is based on the scope and complexity of our engagement with you. Our hourly fee is $250. Our flat fees generally range from $750 to $10,000 (charged annually for ongoing pension consulting services). Alternatively, ongoing services may be charged a percentage of assets under our management according to the schedule below. The fee-paying arrangements will be determined on a case-by-case basis and will be detailed in the advisory agreement. The client will be invoiced directly for the fees. Assets Under Management $0 to $499,999.99 $500,000 to $999,999.99 Over $1,000,000 Annual Percentage of Assets Charge Up to 2.5% Up to 2.0% Up to 1.5% Fees will be billed quarterly via invoice to the client and shall be paid within ten (10) days of the invoice date if fees are not deducted directly from the account. Financial Planning and Consulting We charge on an hourly or flat fee basis for financial planning and consulting services. The total estimated hourly or flat fee, as well as the ultimate fee that we charge, is based on the scope and complexity of our engagement with you. We charge an hourly fee of up to $400 for financial advisors. Flat fees generally range from $500 to $5,000. Fees are billed directly to the client if not deducted from client account. Implementation of the recommendations will be at the discretion of the client. We generally require a retainer of fifty-percent (50%) of the ultimate financial planning or consulting fee with the remainder of the fee directly billed to you and due to us within thirty (30) days of your financial plan being delivered or consultation rendered to you. In all cases, we will not require a retainer exceeding $1,200 when services cannot be rendered within 6 (six) months. LPL Sponsored Advisory Programs As noted in Item 4, the account fee charged to the client for each LPL Financial advisory program varies up to a maximum of 3.00%. Account fees are payable quarterly in advance. Fees are negotiable. The actual fee assessed will be disclosed in the program. LPL Financial serves as program sponsor, investment advisor and broker-dealer for the LPL Financial advisory programs. Our firm and LPL ADV Part 2A – Firm Brochure Page 9 Cornerstone Wealth Management, LLC  Financial share in the account fee and other fees associated with program accounts. Associated persons of our firm may also be registered representatives of LPL. Our firm receives compensation as a result of a client’s participation in an LPL program. Depending on, among other things, the type and size of the account, type of securities held in the account, changes in its value over time, the ability to negotiate fees or commissions, the historical or expected size or number of transactions, and the number and range of supplementary advisory and client- related services provided to the client, the amount of this compensation may be more or less than what our firm would receive if the client participated in other programs, whether through LPL or another sponsor, or paid separately for investment advice, brokerage and other services. The account fee may be higher than the fees charged by other investment advisors for similar services. Clients should consider the level and complexity of the advisory services to be provided when negotiating the account fee (or the advisor fee portion of the account fee, as applicable) with our firm. With regard to accounts utilizing third-party portfolio managers under aggregate, all-in-one account fee structures (including PWP and the legacy MWP fee structure), because the portion of the account fee retained by our firm varies depending on the portfolio strategist fee associated with a portfolio, our firm has a financial incentive to select one portfolio instead of another portfolio. Model Wealth Portfolios Program (MWP) The MWP account fee consists of an LPL program fee, a strategist fee (if applicable) and an advisor fee of up to 2.00%. Accounts remaining under the legacy fee structure may be charged one aggregate account fee, for which the maximum account fee is 2.50%. See the MWP program brochure for more information. Guided Wealth Portfolios Program (GWP) GWP Managed Service clients are charged an account fee consisting of an LPL program fee of 0.35% and an advisor fee of up to 1.00%. In the future, a strategist fee may apply. LPL Research, however, currently serves as the sole portfolio strategist and does not charge a fee for its services. FutureAdvisor is compensated directly by LPL for its services, including the Algorithm and related software, through an annual sub-advisory fee (tiered based on assets under management by FutureAdvisor, at a rate ranging from 0.10% to 0.17%). As each asset tier is reached, LPL’s share of the compensation shall increase, and clients will not benefit from such asset tiers. In the Managed Service of GWP, LPL is appointed by each client as custodian of account assets and broker-dealer with respect to processing securities transactions for the accounts. In general, FutureAdvisor, in its capacity as investment advisor, will submit transactions through LPL; however, FutureAdvisor may choose to execute transactions through a broker-dealer other than LPL, subject to its duty to seek to achieve best execution. When securities transactions are effected through LPL, there are no brokerage commissions charged to the account. If FutureAdvisor chooses to execute a transaction through a broker-dealer other than LPL, the execution price may include a commission or fee imposed by the executing broker-dealer. In evaluating whether to execute a trade through a broker-dealer other than LPL, Future Advisor will consider the fact that the account will not be charged a commission if the transaction is effected through LPL. GWP Educational Tool provides access to sample recommendations at no charge to users. If users decide to implement sample recommendations by executing trades, they will be charged fees, commissions, or expenses by the applicable broker or adviser, as well as underlying investment fees ADV Part 2A – Firm Brochure Page 10 Cornerstone Wealth Management, LLC  and expenses. Account fees are payable quarterly in advance, except that the SMS fee is paid in arrears on the frequency agreed to between client and Advisor. Other Types of Fees & Expenses Non-Wrap Clients will incur transaction fees for trades executed by their chosen custodian, via individual transaction charges. These transaction fees are separate from our firm’s advisory fees and will be disclosed by the chosen custodian. Charles Schwab & Co., Inc. (“Schwab”) does not charge transaction fees for U.S. listed equities and exchange traded funds. Additionally, LPL Financial offers a trading platform with select exchange traded funds (“ETFs”) that do not charge transaction fees. The no-transaction-fee ETF trading platform is available to clients participating in LPL Financial’s Strategic Wealth Management (“SWM”) and Strategic Asset Management (“SAM”) programs. Clients will be subject to transaction fees charged by LPL Financial for ETFs not included in LPL Financial’s platform and for other types of securities. The limited number of ETFs available on LPL Financial’s no-transaction fee platform may have higher overall expenses than other types of securities and ETFs not included in the platform. Other major custodians have eliminated transaction fees for all ETFs and U.S. listed equities, so clients may pay more for investing in the same securities at LPL Financial. Clients may also pay holdings charges imposed by the chosen custodian for certain investments, charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be disclosed in the fund’s prospectus (i.e., fund management fees, initial or deferred sales charges, mutual fund sales loads, 12b-1 fees, surrender charges, variable annuity fees, IRA and qualified retirement plan fees, and other fund expenses), mark-ups and mark-downs, spreads paid to market makers, fees for trades executed away from custodian, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. Our firm does not receive a portion of these fees. Wrap fee clients will receive our Form ADV Part 2A Appendix 1 (the “Managed Asset Program”). Wrap fee clients will not incur transaction costs for trades. More information about this is disclosed in our separate Wrap Fee Program Brochure. Termination & Refunds Either party may terminate the signed advisory agreement for our Asset Management service at any time by providing written notice to the other party. Upon notice of termination, LPL will process a pro-rate refund of the unearned portion of the advisory fees charged in advance at the beginning of the quarter for LPL accounts. Our firm will process a pro-rata refund of the unearned portion of the advisory fees charged in advance for all non-LPL accounts. Financial Planning & Consulting clients may terminate their agreement at any time before the delivery of a financial plan by providing written notice. For purposes of calculating refunds, all work performed by us up to the point of termination shall be calculated at the hourly fee currently in effect. Clients will receive a pro-rata refund of unearned fees based on the time and effort expended by our firm. Either party to a Retirement Plan Consulting Agreement may terminate at any time by providing written notice to the other party. Full refunds will only be made in cases where cancellation occurs within 5 business days of signing an agreement. After 5 business days from initial signing, either party must provide the other party 30 days written notice to terminate billing. Billing will terminate 30 days after receipt of termination notice. Clients will be charged on a pro-rata basis, which takes into account work completed by our firm on behalf of the client. Clients will incur charges for bona ADV Part 2A – Firm Brochure Page 11 Cornerstone Wealth Management, LLC  fide advisory services rendered up to the point of termination (determined as 30 days from receipt of said written notice) and such fees will be due and payable. Commissionable Securities Sales Representatives of our firm are also associated with LPL as broker-dealer registered representatives (“Dually Registered Persons”). In their capacity as registered representatives of LPL, certain Dually Registered Persons may earn commissions for the sale of securities or investment products that they recommend for brokerage clients. They do not earn commissions on the sale of securities or investment products recommended or purchased in advisory accounts through our firm. Clients have the option of purchasing many of the securities and investment products made available through another broker-dealer or investment adviser. When purchasing these securities and investment products away from our firm, however, Clients will not receive the benefit of the advice and other services we provide. Item 6: Performance-Based Fees & Side-By-Side Management We do not charge performance fees to our clients. Item 7: Types of Clients & Account Requirements We have the following types of clients: • Individuals and High Net Worth Individuals; • Trusts, Estates or Charitable Organizations; • Pension and Profit Sharing Plans; • Corporations, limited liability companies and/or other business types; • Other Investment Advisers. Our requirements for opening and maintaining accounts or otherwise engaging us: • We do not require a minimum account balance for our Asset Management service. • We do not charge a minimum fee for written financial plans. • A minimum account value of $5,000 is required to enroll in LPL’s Guided Wealth Portfolios Program (GWP) service. • A minimum account value of $100,000 is required for LPL’s Manager Access Select (“MAS”) service. However, in certain instances, the minimum account size may be lower or higher. • A minimum account value of $10,000 is required for LPL’s Optimum Market Portfolios Program (OMP) service. • A minimum account value of $250,000 is required for LPL’s Personal Wealth Portfolios Program (PWP) service. • A minimum account value of $25,000 is required for LPL’s Model Wealth Portfolios Program (MWP) service. ADV Part 2A – Firm Brochure Page 12 Cornerstone Wealth Management, LLC  Item 8: Methods of Analysis, Investment Strategies & Risk of Loss Methods of Analysis We may use the following methods of analysis in formulating our investment advice and/or managing client assets: Fundamental Analysis. We attempt to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Asset Allocation. Rather than focusing primarily on securities selection, we attempt to identify an appropriate ratio of securities, fixed income, and cash suitable to the client’s investment goals and risk tolerance. A risk of asset allocation is that the client may not participate in sharp increases in a particular security, industry or market sector. Another risk is that the ratio of securities, fixed income, and cash will change over time due to stock and market movements and, if not corrected, will no longer be appropriate for the client’s goals. Mutual Fund and/or ETF Analysis. We look at the experience and track record of the manager of the mutual fund or ETF in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We also look at the underlying assets in a mutual fund or ETF in an attempt to determine if there is significant overlap in the underlying investments held in another fund(s) in the client’s portfolio. We also monitor the funds or ETFs in an attempt to determine if they are continuing to follow their stated investment strategy. A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a fund or ETF, managers of different funds held by the client may purchase the same security, increasing the risk to the client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the holding(s) less suitable for the client’s portfolio. Third-Party Money Manager Analysis. We examine the experience, expertise, investment philosophies, and past performance of independent third-party investment managers in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We monitor the manager’s underlying holdings, strategies, concentrations and leverage as part of our overall periodic risk assessment. Additionally, as part of our due-diligence process, we survey the manager’s compliance and business enterprise risks. A risk of investing with a third-party manager who has been successful in the past is that he/she may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a third-party manager’s portfolio, there is also a risk that a manager may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for our clients. Moreover, as we do not control the manager’s daily business and compliance operations, ADV Part 2A – Firm Brochure Page 13 Cornerstone Wealth Management, LLC  we may be unaware of the lack of internal controls necessary to prevent business, regulatory or reputational deficiencies. Quantitative Analysis. We use quantitative analysis that may include mathematical analysis in an attempt to identify the impact of interest rate changes on individual securities and portfolios of securities. The results of our quantitative analysis are taken into consideration in the decision to buy or sell securities and in the management of portfolio characteristics. A risk in using quantitative analysis is that the methods or models used may be based on assumptions that prove to be incorrect. Qualitative Analysis. We use qualitative analysis to evaluate individual securities, focusing on non- quantifiable factors such as quality of management and others not readily subject to measurement, and incorporate that analysis into our security selection process. A risk in using qualitative analysis is that our subjective judgment may prove incorrect. Asset Allocation. We generally focus on identifying an appropriate allocation of securities, maturities, market sectors and yield curve positioning suitable for the client’s investment goals and risk tolerance. While asset allocation is recognized by professional investment advisers as a prudent approach, a risk of asset allocation is that the client may not participate in sharp increases in a particular security, industry or market sector. Another risk is that the allocation will change over time due to market movements in the various sectors, which, if not corrected, may no longer be appropriate for the client’s goals. Guided Wealth Portfolios Program: At present, the GWP Program is only appropriate for investors with long-term investment horizons, before such investors plan to access assets that are invested pursuant to GWP. If clients need access to the account(s) assets at any point prior to the end of the investment horizon, the prices at which these assets are liquidated may cause a material loss and will negatively compromise the ability to help meet the Investment Objective. The analysis and recommendations provided may be time sensitive, especially during times of significant market volatility and when there are time limits on the availability of a particular investment product. Thus, such analysis and recommendations may be subject to different interpretations as market conditions and other factors change. Investment recommendations can include Mutual Funds and/or ETFs. Investing in such funds involves investment risk as the funds may employ speculative investment techniques, including leverage, concentrated portfolios, investments in workouts or startups, control positions and illiquid investments. The GWP Program is highly reliant on the accurate operation of the Algorithm and the technology that generates the Algorithm. A malfunction or failure in either could cause losses, some or all of which could be significant. The Algorithm employs a number of quantitative models that involve assumptions based upon a limited number of variables that may be extracted from complex financial markets or instruments that they intend to replicate. Any one or all of these assumptions, whether or not supported by past experience, could prove over time to be incorrect, which could result in major losses. While the Algorithm includes a component that seeks to provide recommendations intended to achieve tax efficient asset placement, this component is only one of many that comprise an individual’s comprehensive tax management plan and supplementary tax advice that is outside the scope of the services provided may be necessary to minimize the impact of tax liabilities incurred. The tax efficient investment strategies recommended or implemented in connection with the GWP Program are not intended to be tax advice and do not imply that any particular tax consequences will ADV Part 2A – Firm Brochure Page 14 Cornerstone Wealth Management, LLC  be obtained. Investors should consult with a personal tax advisor regarding the tax consequences of investing. Transactions are placed as soon as reasonably practicable after generating recommendations. There could, however, be material delays in the amount of time it takes to place transactions. Any delays in placing transactions could reduce, perhaps materially, the profit gained from the transaction or could cause a material loss. Transactions are executed by placing “market orders.” A “market order” is an order to buy or sell an investment at the best available price. Because market orders generally are executed immediately (as opposed to an order that specifies a limit price at which the security should be bought or sold and remains open for a longer period of time, during which the price of the security may or may not hit the target price) market orders bear inherent risks, particularly in times of high volatility and for investments that are thinly traded. This could result in paying a higher purchase price or receiving a lower sell price the market orders are placed. It could also result in higher execution fees charged by those handling these transactions. Losses may arise from shortcomings or failures in internal processes, people or systems, or from external events. Operational risk can arise from many factors ranging from routine processing errors to potentially costly incidents related to, for example, major systems failures. There are operational, information security and related risks associated with the increased use of technologies such as the internet to conduct business. In general, cyber incidents can result from deliberate attacks or unintentional events and are not limited to, gaining unauthorized access to digital systems, and misappropriating assets or sensitive information, corrupting data, or causing operational disruption, including the denial-of-service attacks on websites. Cyber security failures or breaches by a third party service provider, any aggregation vendor or the issuers of securities in the account(s), have the ability to cause disruptions and impact business operations, potentially resulting in financial losses, the inability to transact business, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, and/or additional compliance costs, including the cost to prevent cyber incidents. Risks for all forms of analysis. Our securities analysis methods rely on the assumption that the companies whose securities we purchase and sell, the rating agencies that review these securities, and other publicly-available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. Investment Strategies We use the following strategies in managing client accounts, provided that such strategies are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations. Typically, we employ this strategy when: • We believe the securities to be currently undervalued, and/or • We want exposure to a particular asset class over time, regardless of the current projection for this class. Long-term purchases. When utilizing this strategy, we may purchase securities with the idea of holding them for a relatively long time (typically held for at least a year). A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not take advantages of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the decision to sell. Typically, we employ this sub-strategy when we believe the securities to be well valued and/or we want exposure to a ADV Part 2A – Firm Brochure Page 15 Cornerstone Wealth Management, LLC  particular asset class over time, regardless of the current projection for this class. Short-term purchases. When utilizing this strategy, we may also purchase securities with the idea of selling them within a relatively short time (typically a year or less). We do this in an attempt to take advantage of conditions that we believe will soon result in a price swing in the securities we purchase. Trading. We purchase securities with the idea of selling them very quickly (typically within 30 days or less). We do this in an attempt to take advantage of our predictions of brief price swings. Fixed Income Portfolio Management Investment Strategies. We believe that a conservative, risk- averse approach to fixed income management will provide both steady incremental outperformance, and low relative volatility. The disciplined process we employ in an effort to realize this philosophy is generally grounded in four key decisions: 1. Constraint of portfolio duration within a narrow range relative to the benchmark in order to limit exposure to market and interest rate risk. 2. Strategic allocations to key sectors to add value relative to the benchmark. 3. Proactive management of term structure to add value in different yield curve environments. 4. Security selection based on rigorous credit and relative value analysis and broad diversification of nongovernment issuers. Within our Fixed Income strategy, we use the following sub-strategies in managing client accounts, provided that such sub-strategies are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations: Duration Constraints. We adhere to a discipline of generally maintaining duration within a narrow band around benchmark duration in order to limit exposure to market risk. Our portfolio management team rebalances client portfolios to their current duration targets on a periodic basis. The risk of constraining duration is that the client may not participate fully in a large rally in bond prices. Sector Allocation. We allocate client assets to various sectors of the fixed income market, including US Treasury obligations, federal agency securities, corporate notes, mortgage-backed securities and others, based on our quantitative and qualitative analysis in order to manage client exposure to a given sector and to provide exposure to sectors we believe have good value. The risk of sector allocation is that clients may not participate fully in an increase in value in any specific sector. Security Selection. A proprietary credit evaluation process drives our security selection process. The system uses both internally and externally generated credit research to evaluate securities we are considering for purchase. Based on research we conduct internally; our Credit Committee selects securities for our Approved list. The ultimate decision to purchase or sell a security is based on the firm’s evaluation of the current price for the security. The risk of security selection is that the methods of analysis employed will not provide accurate measurement of the risk association with each individual security. Cash Balances. We generally invest client’s cash balances in money market funds, FDIC Insured Certificates of Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, we try to achieve the highest return on our client’s cash balances through relatively low- ADV Part 2A – Firm Brochure Page 16 Cornerstone Wealth Management, LLC  risk conservative investments. In most cases, at least a partial cash balance will be maintained in a money market account so that our firm may debit advisory fees for our services related to asset management, as applicable. Item 9: Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of our advisory business or the integrity of our management. Item 10: Other Financial Industry Activities & Affiliations LPL Financial Representatives of our firm are Dually Registered Persons. LPL is a broker-dealer that is independently owned and operated and is not affiliated with our firm. Please refer to Item 12 for a discussion of the benefits our firm may receive from LPL Financial and the conflicts of interest associated with receipt of such benefits. Occasionally, while advisors move from LPL’s corporate RIA to Cornerstone Wealth Management’s hybrid RIA, they will maintain registrations with both firms during the transition. Insurance Agents Representatives of our firm are insurance agents/brokers. They offer insurance products and receive customary fees as a result of insurance sales. A conflict of interest exists as these insurance sales create an incentive to recommend products based on the compensation adviser and/or our supervised persons may earn. To mitigate this potential conflict, our firm will act in the client’s best interest. In addition, certain representatives of our firm are also licensed with our affiliated insurance entity as insurance agents/brokers. In such capacity, they may offer clients insurance products and receive normal and customary fees as a result of insurance sales. Clients are under no obligation to purchase these products. A conflict of interest exists as these insurance sales create an incentive to recommend products based on the compensation representatives and/or our supervised persons may earn. To mitigate this potential conflict, our firm will act in the client’s best interest. Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading We recognize that the personal investment transactions of members and employees of our firm demand the application of a high Code of Ethics and require that all such transactions be carried out in a way that does not endanger the interest of any client. At the same time, we believe that if investment goals are similar for clients and for members and employees of our firm, it is logical and even desirable that there be common ownership of some securities. ADV Part 2A – Firm Brochure Page 17 Cornerstone Wealth Management, LLC  Therefore, in order to prevent conflicts of interest, we have in place a set of procedures (including a pre- clearing procedure) with respect to transactions effected by our members, officers and employees for their personal accounts. In order to monitor compliance with our personal trading policy, we have a quarterly securities transaction reporting system for all of our associates. Furthermore, our firm has established a Code of Ethics which applies to all of our associated persons. An investment adviser is considered a fiduciary. As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our clients at all times. We have a fiduciary duty to all clients. Our fiduciary duty is considered the core underlying principle for our Code of Ethics which also includes Insider Trading and Personal Securities Transactions Policies and Procedures. We require all of our supervised persons to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws at all times. Upon employment or affiliation and at least annually thereafter, all supervised persons will sign an acknowledgement that they have read, understand, and agree to comply with our Code of Ethics. Our firm and supervised persons must conduct business in an honest, ethical, and fair manner and avoid all circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure is provided to give all clients a summary of our Code of Ethics. However, if a client or a potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon request. Related persons of our firm may buy or sell securities and other investments that are also recommended to clients. In order to minimize this conflict of interest, our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. Similarly, related persons of our firm may buy or sell securities for themselves at or about the same time they buy or sell the same securities for client accounts. In order to minimize this conflict of interest, our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. Further, our related persons will refrain from buying or selling the same securities prior to buying or selling for our clients in the same day unless included in a block trade or its made last thirty minutes of the trading day. Item 12: Brokerage Practices Selecting a Brokerage Firm We seek to recommend a custodian/broker who will hold your assets and execute transactions on terms that are overall most advantageous when compared to other available providers and their services. We consider a wide range of factors, including, among others, these: • Ability to maintain the confidentiality of trading intentions • Timeliness of execution • Timeliness and accuracy of trade confirmations • Liquidity of the securities traded • Willingness to commit capital • Ability to place trades in difficult market environments • Research services provided • Ability to provide investment ideas ADV Part 2A – Firm Brochure Page 18 Cornerstone Wealth Management, LLC  • Execution facilitation services provided • Record keeping services provided • Custody services provided • Frequency and correction of trading errors • Ability to access a variety of market venues • Expertise as it relates to specific securities • Financial condition • Business reputation Our firm generally recommends that Clients establish accounts with LPL Financial (“LPL”), member FINRA/SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. LPL provides brokerage and custodial services to independent investment advisory firms, including our firm. Clients should also be aware that in some limited circumstances, our firm recommends that clients use the Schwab Advisor Services division of Charles Schwab & Co. Inc. (“Schwab”), a FINRA- registered broker-dealer, member SIPC, as the qualified custodian. Our firm is independently owned and operated, and not affiliated with LPL or Schwab. LPL and Schwab will hold client assets in a brokerage account and buy and sell securities when instructed. While our firm recommends that clients use LPL or Schwab as a custodian/broker, clients will decide whether to do so and open an account with LPL or Schwab by entering into an account agreement directly with them. Our firm does not open the account. Even though the account is maintained at LPL or Schwab, our firm can still use other brokers to execute trades, as described below. LPL and Schwab generally do not charge a separate for custody services. Rather, they are compensated by charging commissions or other fees (e.g., trails) to clients on trades that are executed or that settle into the their account(s). However, LPL generally charges account maintenance fees. In addition, LPL also charges clients miscellaneous fees and charges, such as account transfer fees. As for Schwab, in addition to commissions, Schwab charges a flat dollar amount as a “prime broker” or “trade away” fee for each trade that our firm has executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into a Schwab account. These fees are in addition to the commissions or other compensation paid to the executing broker- dealer. While LPL does not participate in, or influence the formulation of, the investment advice our firm provides, certain supervised persons of our firm are Dually Registered Persons. Dually Registered Persons are restricted by certain Financial Industry Regulatory Authority (“FINRA”) rules and policies from maintaining accounts at another custodian or executing transactions in such accounts through any broker-dealer or custodian that is not approved by LPL. As a result, the use of other trading platforms must be approved by our firm and LPL. Clients should also be aware that for accounts where LPL serves as the custodian, our firm is limited to offering services and investment vehicles that are approved by LPL, and may be prohibited from offering services and investment vehicles that may be available through other broker-dealers and custodians, some of which may be more suitable for a client’s portfolio than the services and investment vehicles offered through LPL. Clients should understand that not all investment advisers require that Clients custody their accounts and trade through specific broker-dealers. ADV Part 2A – Firm Brochure Page 19 Cornerstone Wealth Management, LLC  Benefits Received by Our Personnel LPL and Schwab make available to our firm various products and services designed to assist our firm in managing and administering client accounts. Many of these products and services may be used to service all or a substantial number of accounts, including accounts not held with LPL. These include software and other technology that provide access to client account data (such as trade confirmation and account statements); facilitate trade execution (and aggregation and allocation of trade orders for multiple client accounts); provide research, pricing information and other market data; facilitate payment of our firm’s fees from its clients’ accounts; and assist with back-office functions; recordkeeping and client reporting. LPL and Schwab also make available to our firm other services intended to help manage and further develop our business. Some of these services assist our firm to better monitor and service program accounts maintained at LPL or Schwab. Many of these services, however, benefit only our firm. These support services and/or products may be provided without cost, at a discount, and/or at a negotiated rate, and include practice management-related publications; consulting services; attendance at conferences and seminars, meetings, and other educational and/or social events; marketing support; and other products and services used by our firm in furtherance of the operation and development of its investment advisory business. Where such services are provided by a third party vendor, LPL will either make a payment to our firm to cover the cost of such services, reimburse our firm for the cost associated with the services, or pay the third party vendor directly on behalf of our firm. Schwab, on the other hand, will arrange for third-party vendors to provide the services to our firm. Schwab may also discount or waive fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide our firm with other benefits, such as occasional business entertainment for our personnel. The products and services described above are provided to our firm as part of its overall relationship with LPL and Schwab. While as a fiduciary, our firm endeavors to act in its clients’ best interests, the receipt of these benefits creates a conflict of interest because our firm’s requirement that Clients custody their assets at LPL or Schwab is based in part on the benefit to our firm of the availability of the foregoing products and services and not solely on the nature, cost or quality of custody or brokerage services provided by LPL and Schwab. Our firm’s receipt of some of these benefits may be based on the amount of advisory assets custodied on the LPL’s platform or Schwab’s platform. Transition Assistance Benefits LPL provides various benefits and payments to Dually Registered Persons that are new to the LPL platform to assist the representative with the costs (including foregone revenues during account transition) associated with transitioning their business to the LPL platform (collectively referred to as “Transition Assistance”). The proceeds of such Transition Assistance payments are intended to be used for a variety of purposes, including but not necessarily limited to, providing working capital to assist in funding the Dually Registered Person’s business, satisfying any outstanding debt owed to the Dually Registered Person’s prior firm, offsetting account transfer fees (“ACATs”) payable to LPL as a result of the Dually Registered Person’s clients transitioning to LPL’s custodial platform, technology set-up fees, marketing and mailing costs, stationary and licensure transfer fees, moving expenses, office space expenses, staffing support and termination fees associated with moving accounts. ADV Part 2A – Firm Brochure Page 20 Cornerstone Wealth Management, LLC  The Transition Assistance payment amounts are often significant in relation to the overall revenue earned or compensation received by the Dually Registered Person at their prior firm. Such payments are generally based on the size of the Dually Registered Person’s business established at their prior firm and/or assets under custody on the LPL. Please refer to the relevant Part 2B brochure supplement for more information about the specific Transition Payments each representative receives. Transition Assistance payments and other benefits are provided to associated persons of our firm in their capacity as registered representatives of LPL. The receipt of Transition Assistance creates conflicts of interest relating to our firm’s advisory business because it creates a financial incentive to recommend that Clients maintain their accounts with LPL. In certain instances, the receipt of such benefits is dependent on maintaining Client assets with LPL. As such, our firm and its representatives have an incentive to recommend that clients maintain their account with LPL in order to generate such benefits. Our firm attempts to mitigate these conflicts of interest by evaluating and recommending that Clients use LPL’s services based on the benefits that such services provide, rather than the Transition Assistance earned by any particular Dually Registered Person. Our firm considers LPL’s suite of services when recommending that Clients maintain accounts with LPL. Clients should, however, be aware of this conflict and take it into consideration in making a decision whether to custody their assets in a brokerage account at LPL. Our firm does not receive client brokerage commissions (or markups or markdowns) to obtain research or other products or services. We do not receive soft dollars, products or services acquired with client brokerage commissions. Our firm does not receive brokerage for client referrals. We do not allow client-directed brokerage, as trades in our clients’ accounts are executed through LPL Financial or Schwab, qualified custodians and broker-dealers; neither do we direct client transactions to LPL Financial or Schwab in return for soft-dollar benefits. We do not have discretionary authority over the broker or dealer to be used. Special Considerations for ERISA Clients A retirement or ERISA plan client may direct all or part of portfolio transactions for its account through a specific broker or dealer in order to obtain goods or services on behalf of the plan. Such direction is permitted provided that the goods and services provided are reasonable expenses of the plan incurred in the ordinary course of its business for which it otherwise would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the plan. Consequently, we will request that plan sponsors who direct plan brokerage provide us with a letter documenting that this arrangement will be for the exclusive benefit of the plan. Aggregation of Purchase or Sale We do not aggregate the purchase or sale of securities for various client accounts but rather review accounts independently and place transactions accordingly. Whether or not securities are purchased or sold at approximately the same time, all client transactions will incur individual transaction fees. Whether or not we aggregate our orders, LPL Financial does bunch orders. The advantage of bunching is that orders are handled in a way that may mitigate market impact, when applicable and possible. If orders are bunched, each client gets the same average execution price. ADV Part 2A – Firm Brochure Page 21 Cornerstone Wealth Management, LLC  Item 13: Review of Accounts or Financial Plans We review accounts at least annually for our clients subscribing to the Asset Management service. The nature of these reviews is to learn whether clients’ accounts are in line with their investment objectives, appropriately positioned based on market conditions, and investment policies, if applicable. Only our Financial Advisors or Portfolio Managers will conduct reviews. We do not provide written reports to clients, unless asked to do so. Verbal reports to clients take place annually when we contact our clients to conduct a client meeting or conference call. Retirement Consulting and Management clients receive reviews of their pension plans for the duration of the pension consulting service. We also provide ongoing services to Retirement Consulting and Management clients where we meet with such clients upon their request to discuss updates to their plans, changes in their circumstances, etc. Retirement Consulting and Management clients do not receive written or verbal updated reports regarding their pension plans unless they choose to contract with us for ongoing services. Financial Planning clients do not receive reviews of their written plans unless they take action to schedule a financial consultation with us. We do not provide ongoing services to Financial Planning clients, but are willing to meet with such clients upon their request to discuss updates to their plans, changes in their circumstances, etc. Financial planning clients do not receive written or verbal updated reports regarding their financial plans unless they separately contract with us for a post- financial plan meeting or update to their initial written financial plan. We may review client accounts more frequently than described above. Among the factors which may trigger an off-cycle review are major market or economic events, the client’s life events, requests by the client, etc. Item 14: Client Referrals & Other Compensation LPL Financial, LLC We may receive from LPL or a mutual fund company, without cost and/or at a discount support services and/or products, to assist us to better monitor and service client accounts maintained at such institutions. Included within the support services we may receive investment-related research, pricing information and market data, software and other technology that provide access to client account data, compliance and/or practice management-related publications, discounted or gratis consulting services, discounted and/or gratis attendance at conferences, meetings, and other educational and/or social events, marketing support, computer hardware and/or software and/or other products used by us to assist us in our investment advisory business operations. Additionally, LPL may compensate our firm for on boarding advisors. Our clients do not pay more for investment transactions effected and/or assets maintained at LPL as result of this arrangement. There is no commitment made by us to LPL or any other institution as a result of the above arrangement. Our firm and its Dually Registered Persons are incented to join and remain affiliated with LPL and to recommend that Clients establish accounts with LPL through the provision of Transition Assistance ADV Part 2A – Firm Brochure Page 22 Cornerstone Wealth Management, LLC  (discussed in Item 12 above). LPL also provides other compensation to our firm and its Dually Registered Persons, including but not limited to, bonus payments, repayable and forgivable loans, stock awards and other benefits. The receipt of any such compensation creates a financial incentive for your representative to recommend LPL as custodian for the assets in your advisory account. Our firm encourages you to discuss any such conflicts of interest with your representative before making a decision to custody your assets at LPL. Schwab Our firm receives economic benefit from Schwab 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. These products and services, how they benefit our firm, and the related conflicts of interest are described above (see Item 12 – Brokerage Practices). The availability of Schwab’s products and services is not based on our firm giving particular investment advice, such as buying particular securities for our clients. Third-Party Trust Service Providers Our firm does not provide trust administration services, but seeks to assist clients in meeting their financial and estate planning needs. As part of this effort, we make Visible National Trust, a third- party provider specializing in special needs trust services, available to clients who require such services. Clients are under no obligation to use Visible National Trust and may select any trust company or fiduciary of their choosing. If a client elects to engage Visible National Trust, they will enter into a separate trust agreement directly with that entity. Our firm does not control or supervise the services provided by Visible National Trust and does not assume responsibility for their terms, fees, or services. Our firm’s financial advisors will receive compensation for investment management services provided to clients who establish trust accounts with Visible National Trust. While this compensation is paid by the client, Visible National Trust may facilitate its remittance as part of its trust administration services. This arrangement does not affect the fees paid by the client but does create a potential conflict of interest, as our firm and its financial advisors have a financial incentive to recommend Visible National Trust over other trust service providers. To mitigate this conflict, clients are encouraged to conduct independent due diligence and consider multiple trust providers before making a selection. Referral Fees In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm provides cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or endorsements (which include client referrals). Such compensation arrangements will not result in higher costs to the referred client. In this regard, our firm maintains a written agreement with each unaffiliated person that is compensated for testimonials or endorsements in an aggregate amount of $1,000 or more (or the equivalent value in non-cash compensation) over a trailing 12-month period in compliance with Rule 206 (4)-1 of the Investment Advisers Act of 1940 and applicable state and federal laws. The following information will be disclosed clearly and prominently to referred prospective clients at the time of each testimonial or endorsement: ADV Part 2A – Firm Brochure Page 23 Cornerstone Wealth Management, LLC  • Whether or not the unaffiliated person is a current client of our firm, • A description of the cash or non-cash compensation provided directly or indirectly by our firm to the unaffiliated person in exchange for the referral, if applicable, and • A brief statement of any material conflicts of interest on the part of the unaffiliated person giving the referral resulting from our firm’s relationship with such unaffiliated person. In cases where state law requires licensure of solicitors, our firm ensures that no solicitation fees are paid unless the solicitor is registered as an investment adviser representative of our firm. If our firm is paying solicitation fees to another registered investment adviser, the licensure of individuals is the other firm’s responsibility. Item 15: Custody All of our clients receive account statements directly from their qualified custodians at least quarterly upon opening of an account. If our firm decides to also send account statements to clients, such notice and account statements include a legend that recommends that the client compare the account statements received from the qualified custodian with those received from our firm. The custodians we do business with will send you independent account statements listing your account balance(s), transaction history and any fee debits or other fees taken out of your account. Third Party Money Movement: On February 21, 2017, the SEC issued a no‐action letter (“Letter”) with respect to Rule 206(4)‐2 (“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client funds to a third party under a standing letter of authorization (“SLOA”) is deemed to have custody. As such, our firm has adopted the following safeguards in conjunction with our custodian(s): • 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. • 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. • 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. • The client has the ability to terminate or change the instruction to the client’s qualified custodian. • 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. • The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. • The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. ADV Part 2A – Firm Brochure Page 24 Cornerstone Wealth Management, LLC  Clients are encouraged to raise any questions with us about the custody, safety or security of their assets and our custodial recommendations. Item 16: Investment Discretion Clients have the option of providing our firm with investment discretion on their behalf, pursuant to an executed investment advisory client agreement for our Asset Management and some Third Party Referral Services. By granting investment discretion, our firm is authorized to execute securities transactions, determine which securities are bought and sold, and the total amount to be bought and sold. Should clients grant our firm non-discretionary authority, our firm would be required to obtain the client’s permission prior to effecting securities transactions. Limitations may be imposed by the client in the form of specific constraints on any of these areas of discretion with our firm’s written acknowledgement. Item 17: Voting Client Securities We do not accept the proxy authority to vote client securities. Clients will receive proxies or other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent to our firm, we will forward them on to you and ask the party who sent them to mail them directly to you in the future. Clients may call, write or email us to discuss questions they may have about particular proxy votes or other solicitations. However, third party money managers selected or recommended by our firm may vote proxies for clients. Therefore, except in the event a third-party money manager votes proxies, clients maintain exclusive responsibility for: (1) directing the manner in which proxies solicited by issuers of securities beneficially owned by the client shall be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s investment assets. Therefore (except for proxies that may be voted by a third-party money manager), our firm and/or you shall instruct your qualified custodian to forward to you copies of all proxies and shareholder communications relating to your investment assets. Item 18: Financial Information We do not require, nor do we solicit prepayment of more than $1,200 in fees per client, six months or more in advance. Therefore, we have not included a balance sheet for our most recent fiscal year. Cornerstone Wealth Management, LLC has never been subject to a bankruptcy petition. ADV Part 2A – Firm Brochure Page 25 Cornerstone Wealth Management, LLC 

Item 1: Cover Page Part 2A Appendix 1 of Form ADV: Wrap Fee Program Brochure April 2025 7417 Mexico Road, Suite 104 St. Peters, MO 63376 Firm Contact: Thomas Gooden Chief Compliance Officer This Managed Asset Program Brochure (Form ADV Part 2A Appendix 1) provides information about the qualifications and business practices of Cornerstone Wealth Management, LLC. If you have any questions about the contents of this brochure, please contact us by telephone at (636) 397-6200 or email at thomas.gooden@lpl.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any State Securities Authority. Additional information about Cornerstone Wealth Management, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD #164666. Please note use of the term “registered investment adviser” and description of Cornerstone Wealth Management, LLC and/or our associates as “registered” does not imply a certain level of skill or training. You are encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise you for more information on the qualifications of our firm and its employees.  Item 2: Material Changes Cornerstone Wealth Management, LLC is required to advise you of any material changes to our Managed Asset Program Brochure (“MAP Brochure”) from our last annual update, identify those changes on the cover page of our MAP Brochure or on the page immediately following the cover page, or in a separate communication accompanying our MAP Brochure. Since the last annual amendment filed on 03/28/2024, the following material change(s) have been made: • We have updated Item 4 to disclose that our firm will manage certain client account(s) that are held at a custodian that is not directly accessible by our firm using Pontera Solutions, Inc. (“Pontera”)’s order management system. The advisory fee payable for any held away accounts will be deducted directly from another client account. If there are insufficient funds available in another client account or our firm believes that deducting the advisory fee from another client account would be prohibited by applicable law, we will invoice the client directly. Please see Item 4 for additional information. • Our firm has established an arrangement where we recommend Visible National Trust, a third-party provider specializing in special needs trust services, to clients who require such services. If a client elects to engage Visible National Trust, they will enter into a separate trust agreement directly with that entity. Our firm’s financial advisors will receive compensation for investment management services provided to clients who establish trust accounts with Visible National Trust. Our firm and its financial advisors therefore have a financial incentive to recommend Visible National Trust over other trust service providers. To mitigate this conflict, clients are encouraged to conduct independent due diligence and consider multiple trust providers before making a selection. Please see Item 9 for additional information. ADV Part 2A Appendix 1– Managed Asset Program Brochure Page 2 Cornerstone Wealth Management, LLC  Item 3: Table of Contents Page(s): Topic: Item 1: Cover Page for Part 2A Appendix 1 of Form ADV ....................................................................................... 1 Item 2: Material Changes ...................................................................................................................................................... 2 Item 3: Table of Contents ..................................................................................................................................................... 3 Item 4: Services, Fees & Compensation .......................................................................................................................... 4 Item 5: Account Requirements & Types of Clients .................................................................................................... 7 Item 6: Portfolio Manager Selection & Evaluation ..................................................................................................... 7 Item 7: Client Information Provided to Portfolio Manager .................................................................................. 11 Item 8: Client Contact with Portfolio Manager .......................................................................................................... 11 Item 9: Additional Information ........................................................................................................................................ 11 ADV Part 2A Appendix 1– Managed Asset Program Brochure Page 3 Cornerstone Wealth Management, LLC  Our firm also conducts business under the following names: Vine Wealth Management Milestone Investment Counsel Carlisle Mott Financial Stauros Financial, LLC Legends Financial Services Group, LLC Focus Wealth Management Rains Wealth Management Stockyard Wealth Management Triada Advisors Stone 8 Wealth Management, LLC Dixon Incorporated Bell & Associates Wealth Management Steamboat Financial Group GenFinity Wealth Management Lifetime Planning, Inc. Morse Wealth Management West Financial Services Item 4: Services, Fees & Compensation Our firm manages assets for many different types of clients to help meet their financial goals while remaining sensitive to risk tolerance and time horizons. As a fiduciary, it is our duty to always act in the client’s best interest. This is accomplished in part by knowing the client. Our firm has established a service-oriented advisory practice with open lines of communication. Working with clients to understand their investment objectives while educating them about our process, facilitates the kind of working relationship we value. Our firm sponsors and offers a wrap fee program, which allows clients to pay a single fee for investment advisory services and associated custodial transaction costs. Transaction fees will be paid by our firm via individual transaction charges. Because our firm absorbs client transaction fees, an incentive exists to limit trading activities in client accounts. Custodial transaction costs, however, are not included in the advisory fee charged by our firm for non-wrap services, and are to be paid by the client to their chosen custodian. Depending on the client’s account or portfolio trading activity, clients may pay more for using our wrap fee services than they would for using our non-wrap services. LPL Financial offers a trading platform with select exchange traded funds (“ETFs”) that do not charge transaction fees. The no-transaction-fee ETF trading platform is available to clients participating in LPL Financial’s Strategic Wealth Management (“SWM”) and Strategic Asset Management (“SAM”) programs. Since our firm pays the transaction fees charged by LPL Financial to clients participating in our wrap fee program, we are incentivized to recommend no-transaction-fee ETFs over other types of securities and ETFs in order to reduce our costs. It is important for the client to understand that this presents a conflict of interest because the limited number of ETFs available on the no- transaction fee platform may have higher overall expenses than other types of securities and ETFs not included in the platform. In addition, other major custodians have eliminated transaction fees for all ETFs and U.S. equities, so clients may pay more for investing in the same securities at LPL Financial. Our firm may recommend Charles Schwab & Co., Inc. (“Schwab”) as an alternative custodian to LPL for clients who are otherwise prohibited from holding investments at LPL. Schwab does not charge transaction fees for U.S. listed equities and exchange traded funds. Since we pay the transaction fees charged by Schwab to clients participating in our wrap fee program, this presents a conflict of interest because we are incentivized to recommend equities and exchange traded funds over other types of securities in order to reduce our costs. ADV Part 2A Appendix 1– Managed Asset Program Brochure Page 4 Cornerstone Wealth Management, LLC  Our Wrap Advisory Services Our Managed Asset Program We emphasize continuous and regular account supervision. As part of our asset management service, we generally create a portfolio, consisting of individual stocks or bonds, exchange traded funds (“ETFs”), options, mutual funds and other public and private securities or investments. We also provide investment management services for plan participants’ 401(k)s including rollover options and the risks of moving assets out of 401(k) plans. The client’s individual investment strategy is tailored to their specific needs and may include some or all of the previously mentioned securities. Each portfolio will be initially designed to meet a particular investment goal, which we determine to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, we review the portfolio at least annually and if necessary, rebalance the portfolio based upon the client’s individual needs, stated goals, and objectives. Each client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Our Managed Asset Program maximum fee schedule: Assets Under Management $0 to $499,999.99 $500,000 to $999,999.99 Over $1,000,000 Annual Percentage of Assets Charge Up to 2.4% Up to 1.9% Up to 1.4% For LPL Accounts: The fee to be assessed to each account will be detailed in the client’s signed advisory agreement, LPL Account Application, or LPL Tiered Fee Authorization form. Fees are billed on a pro-rata basis quarterly in advance based on the value of the account(s) on the last day of the previous quarter. Fees are negotiable and will be deducted from the account(s). We bill on cash or cash equivalents unless otherwise indicated in writing. Fees are adjusted for deposits and withdrawals made during the quarter. If accounts are opened during the quarter, the pro-rata advisory fees will be deducted during the next regularly scheduled billing cycle. Our firm does not offer direct invoicing. As part of the fee deduction process, clients understand the following: a) LPL as the client’s custodian sends statements at least quarterly, showing all disbursements for each account, including the amount of the advisory fees paid to our firm. b) Clients provide authorization permitting LPL to deduct these fees. c) LPL calculates the advisory fees for all fee schedules and deducts them from the client’s account. For Schwab Accounts: Fees to be assessed will be outlined in the advisory agreement to be signed by the client. Annualized fees are billed on a pro-rata basis quarterly in advance based on the value of the account(s) on the last day of the previous quarter. Fees are negotiable and will be deducted from client account(s). We bill on cash or cash equivalents unless otherwise indicated in writing. Fees are not adjusted for deposits and withdrawals made during the quarter. Our firm does not offer direct invoicing. As part of the fee deduction process, clients understand the following: ADV Part 2A Appendix 1– Managed Asset Program Brochure Page 5 Cornerstone Wealth Management, LLC  a) The client’s independent custodian sends statements at least quarterly showing the market values for each security included in the assets and all account disbursements, including the amount of the advisory fees paid to our firm. b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our firm will send an invoice directly to the custodian. c) If we send a copy of our invoice to the client, our invoice will include a disclosure urging the client to compare the information provided in our statement with those from the qualified custodian. In certain cases, our firm will manage client account(s) that are held at a custodian that is not directly accessible by our firm using Pontera Solutions, Inc. (“Pontera”)’s order management system. The advisory fee payable for any held away accounts will be deducted directly from another client account. If there are insufficient funds available in another client account or our firm believes that deducting the advisory fee from another client account would be prohibited by applicable law, we will invoice the client directly. Our Managed Asset Program allows our clients to pay a specified fee for investment advisory services and the execution of transactions. The fee is not based directly upon transactions in your account. Your fee is bundled with our costs for executing transactions in your account(s). This results in a higher advisory fee to you. We do not charge our clients higher advisory fees based on their trading activity, but you should be aware that we may have an incentive to limit our trading activities in your account(s) because we are charged for executed trades. By participating in our Managed Asset Program, you may end up paying more or less than you would through a non-wrap fee program where a lower advisory fee is charged, but trade execution costs are passed directly through to you by the executing broker. You may pay custodial fees, charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses), mark-ups and mark-downs, spreads paid to market makers, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. These fees are not included within the Managed Asset Program fee you are charged by our firm. Our investment advisory representatives receive a portion of the advisory fee that you pay us, either directly as a percentage of your overall fee or as their salary from our firm. In cases where our investment advisory representatives are paid a percentage of your overall advisory fee, this may create an incentive to recommend that you participate in our Managed Asset Program rather than a non-wrap fee program (where you would pay for trade execution costs) or brokerage account where commissions are charged. This is because, in some cases, we may stand to earn more compensation from advisory fees paid to us through our Managed Asset Program arrangement if your account is not actively traded. Termination & Refunds Either party may terminate the signed advisory agreement for our Managed Asset Program service at any time by providing written notice to the other party. Upon notice of termination, LPL will process a pro-rate refund of the unearned portion of the advisory fees charged in advance at the beginning of the quarter for LPL accounts. Our firm will process a pro-rata refund of the unearned portion of the advisory fees charged in advance for Schwab accounts. ADV Part 2A Appendix 1– Managed Asset Program Brochure Page 6 Cornerstone Wealth Management, LLC  Item 5: Account Requirements & Types of Clients We do not impose minimum account size to open or maintain an account with us. The types of clients we typically manage accounts on behalf of, include: • Individuals and High Net Worth Individuals; • Trusts, Estates or Charitable Organizations; • Pension and Profit Sharing Plans; • Corporations, limited liability companies and/or other business types; • Other Investment Advisers. Item 6: Portfolio Manager Selection & Evaluation Selection of Portfolio Managers: Our firm’s investment adviser representatives (“IARs”) act as portfolio manager(s) for this wrap fee program. A conflict arises in that other investment advisory firms may charge the same or lower fees than our firm for similar services. Our IARs are subject to individual licensing requirements as imposed by state securities boards. Our firm is required to confirm or update each IAR’s Form U4 on an annual basis. IAR supervision is conducted by our Chief Compliance Officer or management personnel. Our firm does not utilize outside portfolio managers. All accounts are managed by our in-house licensed investment adviser representatives (“IARs”) of our firm. Prior to becoming licensed with our firm, each IARs industry experience, licensure, outside business activities, client complaints (if any), disciplinary or regulatory history (if any) and financial well-being will be reviewed. Each IAR will then have a Form U4 and ADV Part 2B on file with our firm. Performance returns of wrap portfolios are reviewed at least quarterly. The nature of these reviews is to learn whether client accounts are in line with their investment objectives and appropriately positioned based on market conditions. If these standards fall below the client objectives, our firm will discuss the review with the portfolio manager for proactive action to realign the investment strategy. Tailoring of Advisory Services and Participation in Wrap Fee Programs We offer individualized investment advice to clients utilizing the Managed Asset Program services. All accounts are managed according to the client’s investment objectives, financial goals, risk tolerance, etc. We do not manage Managed Asset Program accounts in a different fashion than non- wrap fee accounts. Each client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account. ADV Part 2A Appendix 1– Managed Asset Program Brochure Page 7 Cornerstone Wealth Management, LLC  Performance-based fees and side-by-side management We do not charge performance fees to our clients. Methods of Analysis, Investment Strategies & Risk of Loss Methods of Analysis. We may use the following methods of analysis in formulating our investment advice and/or managing client assets: Fundamental Analysis. We attempt to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Asset Allocation. Rather than focusing primarily on securities selection, we attempt to identify an appropriate ratio of securities, fixed income, and cash suitable to the client’s investment goals and risk tolerance. A risk of asset allocation is that the client may not participate in sharp increases in a particular security, industry or market sector. Another risk is that the ratio of securities, fixed income, and cash will change over time due to stock and market movements and, if not corrected, will no longer be appropriate for the client’s goals. Mutual Fund and/or ETF Analysis. We look at the experience and track record of the manager of the mutual fund or ETF in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We also look at the underlying assets in a mutual fund or ETF in an attempt to determine if there is significant overlap in the underlying investments held in another fund(s) in the client’s portfolio. We also monitor the funds or ETFs in an attempt to determine if they are continuing to follow their stated investment strategy. A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a fund or ETF, managers of different funds held by the client may purchase the same security, increasing the risk to the client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the holding(s) less suitable for the client’s portfolio. Quantitative Analysis. We use quantitative analysis that may include mathematical analysis in an attempt to identify the impact of interest rate changes on individual securities and portfolios of securities. The results of our quantitative analysis are taken into consideration in the decision to buy or sell securities and in the management of portfolio characteristics. A risk in using quantitative analysis is that the methods or models used may be based on assumptions that prove to be incorrect. Qualitative Analysis. We use qualitative analysis to evaluate individual securities, focusing on non- quantifiable factors such as quality of management and others not readily subject to measurement, and incorporate that analysis into our security selection process. A risk in using qualitative analysis is that our subjective judgment may prove incorrect. ADV Part 2A Appendix 1– Managed Asset Program Brochure Page 8 Cornerstone Wealth Management, LLC  Asset Allocation. We generally focus on identifying an appropriate allocation of securities, maturities, market sectors and yield curve positioning suitable for the client’s investment goals and risk tolerance. While asset allocation is recognized by professional investment advisers as a prudent approach, a risk of asset allocation is that the client may not participate in sharp increases in a particular security, industry or market sector. Another risk is that the allocation will change over time due to market movements in the various sectors, which, if not corrected, may no longer be appropriate for the client’s goals. Risks for all forms of analysis. Our securities analysis methods rely on the assumption that the companies whose securities we purchase and sell, the rating agencies that review these securities, and other publicly-available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. Investment Strategies We use the following strategies in managing client accounts, provided that such strategies are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations. Typically, we employ this strategy when: • We believe the securities to be currently undervalued, and/or • We want exposure to a particular asset class over time, regardless of the current projection for this class. Long-term purchases. When utilizing this strategy, we may purchase securities with the idea of holding them for a relatively long time (typically held for at least a year). A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not take advantages of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the decision to sell. Typically, we employ this sub-strategy when we believe the securities to be well valued and/or we want exposure to a particular asset class over time, regardless of the current projection for this class. Margin Loans: Our firm may allow or recommend that you to pledge securities from your portfolio as collateral for a loan by using margin in brokerage account. This allows you to own more stock than you would be able to with your available cash. Margin accounts and transactions are risky and not necessarily appropriate for every client. The potential risks associated with these transactions are (1) You can lose more funds than are deposited into the margin account; (2) the forced sale of securities or other assets in your account; (3) the sale of securities or other assets without contacting you; (4) you may not be entitled to choose which securities or other assets in your account(s) are liquidated or sold to meet a margin call; and (5) custodians charge interest on margin balances which will reduce your returns over time. Short-term purchases. When utilizing this strategy, we may also purchase securities with the idea of selling them within a relatively short time (typically a year or less). We do this in an attempt to take advantage of conditions that we believe will soon result in a price swing in the securities we purchase. ADV Part 2A Appendix 1– Managed Asset Program Brochure Page 9 Cornerstone Wealth Management, LLC  Trading. We purchase securities with the idea of selling them very quickly (typically within 30 days or less). We do this in an attempt to take advantage of our predictions of brief price swings. Fixed Income Portfolio Management Investment Strategies. We believe that a conservative, risk- averse approach to fixed income management will provide both steady incremental outperformance, and low relative volatility. The disciplined process we employ in an effort to realize this philosophy is generally grounded in four key decisions: 1. Constraint of portfolio duration within a narrow range relative to the benchmark in order to limit exposure to market and interest rate risk. 2. Strategic allocations to key sectors to add value relative to the benchmark. 3. Proactive management of term structure to add value in different yield curve environments. 4. Security selection based on rigorous credit and relative value analysis and broad diversification of nongovernment issuers. Within our Fixed Income strategy, we use the following sub-strategies in managing client accounts, provided that such sub-strategies are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations: Duration Constraints. We adhere to a discipline of generally maintaining duration within a narrow band around benchmark duration in order to limit exposure to market risk. Our portfolio management team rebalances client portfolios to their current duration targets on a periodic basis. The risk of constraining duration is that the client may not participate fully in a large rally in bond prices. Sector Allocation. We allocate client assets to various sectors of the fixed income market, including US Treasury obligations, federal agency securities, corporate notes, mortgage-backed securities and others, based on our quantitative and qualitative analysis in order to manage client exposure to a given sector and to provide exposure to sectors we believe have good value. The risk of sector allocation is that clients may not participate fully in an increase in value in any specific sector. Security Selection. A proprietary credit evaluation process drives our security selection process. The system uses both internally and externally generated credit research to evaluate securities we are considering for purchase. Based on research we conduct internally; our Credit Committee selects securities for our Approved list. The ultimate decision to purchase or sell a security is based on the firm’s evaluation of the current price for the security. The risk of security selection is that the methods of analysis employed will not provide accurate measurement of the risk association with each individual security. Cash Balances. We generally invest client’s cash balances in money market funds, FDIC Insured Certificates of Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, we try to achieve the highest return on our client’s cash balances through relatively low- risk conservative investments. In most cases, at least a partial cash balance will be maintained in a money market account so that our firm may debit advisory fees for our services related to asset management, as applicable. Voting Client Securities We do not accept the proxy authority to vote client securities. Clients will receive proxies or other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent to our ADV Part 2A Appendix 1– Managed Asset Program Brochure Page 10 Cornerstone Wealth Management, LLC  firm, we will forward them on to you and ask the party who sent them to mail them directly to you in the future. Clients may call, write or email us to discuss questions they may have about particular proxy votes or other solicitations. Item 7: Client Information Provided to Portfolio Manager All accounts are managed by our in-house licensed IARs. The IAR selected to manage the client’s account(s) or portfolio(s) will be privy to the client’s investment goals and objectives, risk tolerance, restrictions placed on the management of the account(s) or portfolio(s) and relevant client notes taken by our firm. Please see our firm’s Privacy Policy for more information on how our firm utilizes client information. Item 8: Client Contact with Portfolio Manager Clients are always free to directly contact our firm with questions or concerns about their portfolios or other matters. Item 9: Additional Information Disciplinary Information We have determined that our firm and management have no disciplinary information to disclose. Financial Industry Activities & Affiliations Since we participate in LPL Financial’s hybrid RIA program the majority of our investment adviser representatives are also registered representatives with LPL, through which all brokerage transactions will be implemented. Investment adviser representatives are required to implement brokerage trades in this manner as a result of them being registered representatives with LPL. This relationship will be disclosed to all clients during their on boarding process. As a result of this relationship, we do not recommend directed brokerage trades, negotiating fees or commissions or receiving additional incentives from other broker/dealers for trades executed through them. However, clients will be made aware that as registered representatives, the investment adviser representatives receive services including but not limited to: administrative functions including portfolio pricing, account statement generation, fee calculations, back-office support, trade execution and research. Clients are not obligated to implement transactions through the investment adviser representatives in their separate capacities as registered representatives. Clients’ trades will always be implemented based on the goals and objectives of the client and not on the incentives to the representatives for implementing the trades. Our firm’s management persons will only receive commissions for securities recommendations they make to brokerage clients in non-advisory accounts. As a result of this relationship, LPL Financial may have access to certain confidential information (e.g., financial information, investment objectives, transactions and holdings) about ADV Part 2A Appendix 1– Managed Asset Program Brochure Page 11 Cornerstone Wealth Management, LLC  clients, even if client does not establish any account through LPL, for regulatory purposes. If you would like a copy of the LPL Financial privacy policy, please contact Gregory Shoemaker. Occasionally, while advisors move from LPL’s corporate RIA to Cornerstone Wealth Management’s hybrid RIA, they will maintain registrations with both firms during the transition. Our advisory representatives may also be licensed to sell insurance products. As such, they may have an incentive to sell and recommend insurance products to advisory clients. When such recommendations or sales are made, a conflict of interest exists as our representative may earn insurance commissions for the sale of those products. Clients are under no obligation to purchase insurance products recommended to them by our advisory representatives. Code of Ethics, Participation or Interest in Client Transactions & Personal Trading We recognize that the personal investment transactions of members and employees of our firm demand the application of a high Code of Ethics and require that all such transactions be carried out in a way that does not endanger the interest of any client. At the same time, we believe that if investment goals are similar for clients and for members and employees of our firm, it is logical and even desirable that there be common ownership of some securities. Therefore, in order to prevent conflicts of interest, we have in place a set of procedures (including a pre- clearing procedure) with respect to transactions effected by our members, officers and employees for their personal accounts. In order to monitor compliance with our personal trading policy, we have a quarterly securities transaction reporting system for all of our associates. Furthermore, our firm has established a Code of Ethics which applies to all of our associated persons. An investment adviser is considered a fiduciary. As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our clients at all times. We have a fiduciary duty to all clients. Our fiduciary duty is considered the core underlying principle for our Code of Ethics which also includes Insider Trading and Personal Securities Transactions Policies and Procedures. We require all of our supervised persons to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws at all times. Upon employment or affiliation and at least annually thereafter, all supervised persons will sign an acknowledgement that they have read, understand, and agree to comply with our Code of Ethics. Our firm and supervised persons must conduct business in an honest, ethical, and fair manner and avoid all circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure is provided to give all clients a summary of our Code of Ethics. However, if a client or a potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon request. Related persons of our firm may buy or sell securities and other investments that are also recommended to clients. In order to minimize this conflict of interest, our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. Similarly, related persons of our firm may buy or sell securities for themselves at or about the same time they buy or sell the same securities for client accounts. In order to minimize this conflict of interest, our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. Further, our related persons will refrain from buying or selling the same securities prior to buying or selling for our clients in the same day. If related persons’ accounts are included in a block trade, our related persons will always trade personal accounts last. ADV Part 2A Appendix 1– Managed Asset Program Brochure Page 12 Cornerstone Wealth Management, LLC  Review of Accounts We review accounts on at least an annual basis for our clients subscribing to our Managed Asset Program. The nature of these reviews is to learn whether clients’ accounts are in line with their investment objectives, appropriately positioned based on market conditions, and investment policies, if applicable. Only our Financial Advisors or Portfolio Managers will conduct reviews. We do not provide written reports to clients, unless asked to do so. Verbal reports to clients take place on at least an annual basis when we contact our clients. We may review client accounts more frequently than described above. Among the factors which may trigger an off-cycle review are major market or economic events, the client’s life events, requests by the client, etc. Client Referrals & Other Compensation Referral Fees In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm provides cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or endorsements (which include client referrals). Such compensation arrangements will not result in higher costs to the referred client. In this regard, our firm maintains a written agreement with each unaffiliated person that is compensated for testimonials or endorsements in an aggregate amount of $1,000 or more (or the equivalent value in non-cash compensation) over a trailing 12-month period in compliance with Rule 206 (4)-1 of the Investment Advisers Act of 1940 and applicable state and federal laws. The following information will be disclosed clearly and prominently to referred prospective clients at the time of each testimonial or endorsement: • Whether or not the unaffiliated person is a current client of our firm, • A description of the cash or non-cash compensation provided directly or indirectly by our firm to the unaffiliated person in exchange for the referral, if applicable, and • A brief statement of any material conflicts of interest on the part of the unaffiliated person giving the referral resulting from our firm’s relationship with such unaffiliated person. In cases where state law requires licensure of solicitors, our firm ensures that no solicitation fees are paid unless the solicitor is registered as an investment adviser representative of our firm. If our firm is paying solicitation fees to another registered investment adviser, the licensure of individuals is the other firm’s responsibility. LPL Financial We may receive from LPL or a mutual fund company, without cost and/or at a discount support services and/or products, to assist us to better monitor and service client accounts maintained at such institutions. Included within the support services we may receive investment-related research, pricing information and market data, software and other technology that provide access to client account data, compliance and/or practice management-related publications, discounted or gratis consulting services, discounted and/or gratis attendance at conferences, meetings, and other educational and/or social events, marketing support, computer hardware and/or software and/or other products used by us to assist us in our investment advisory business operations. Additionally, LPL may compensate our firm for on boarding advisors. Our clients do not pay more for investment ADV Part 2A Appendix 1– Managed Asset Program Brochure Page 13 Cornerstone Wealth Management, LLC  transactions effected and/or assets maintained at LPL as result of this arrangement. There is no commitment made by us to LPL or any other institution as a result of the above arrangement. Our firm and its Dually Registered Persons are incented to join and remain affiliated with LPL and to recommend that Clients establish accounts with LPL through the provision of Transition Assistance (discussed in Item 12 above). LPL also provides other compensation to our firm and its Dually Registered Persons, including but not limited to, bonus payments, repayable and forgivable loans, stock awards and other benefits. The receipt of any such compensation creates a financial incentive for your representative to recommend LPL as custodian for the assets in your advisory account. Our firm encourages you to discuss any such conflicts of interest with your representative before making a decision to custody your assets at LPL. Schwab Our firm receives economic benefit from Schwab 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. These products and services, how they benefit our firm, and the related conflicts of interest are described in Form ADV Part 2A, Item 12 – Brokerage Practices. The availability of Schwab’s products and services is not based on our firm giving particular investment advice, such as buying particular securities for our clients. Third-Party Trust Service Providers Our firm does not provide trust administration services, but seeks to assist clients in meeting their financial and estate planning needs. As part of this effort, we make Visible National Trust, a third- party provider specializing in special needs trust services, available to clients who require such services. Clients are under no obligation to use Visible National Trust and may select any trust company or fiduciary of their choosing. If a client elects to engage Visible National Trust, they will enter into a separate trust agreement directly with that entity. Our firm does not control or supervise the services provided by Visible National Trust and does not assume responsibility for their terms, fees, or services. Our firm’s financial advisors will receive compensation for investment management services provided to clients who establish trust accounts with Visible National Trust. While this compensation is paid by the client, Visible National Trust may facilitate its remittance as part of its trust administration services. This arrangement does not affect the fees paid by the client but does create a potential conflict of interest, as our firm and its financial advisors have a financial incentive to recommend Visible National Trust over other trust service providers. To mitigate this conflict, clients are encouraged to conduct independent due diligence and consider multiple trust providers before making a selection. Financial Information We do not require, nor do we solicit prepayment of more than $1,200 in fees per client, six months or more in advance. Therefore, we have not included a balance sheet for our most recent fiscal year. Cornerstone Wealth Management, LLC has never been subject to a bankruptcy petition. ADV Part 2A Appendix 1– Managed Asset Program Brochure Page 14 Cornerstone Wealth Management, LLC