CRAFT & SAGE WEALTH

Craft & Sage Wealth Craft & Sage Wealth 2500 Summit Street,# 103 Kansas City, MO 64108 www.craftandsage.com 816.436.9939 October 1, 2025 Item 1: Firm Brochure (Form ADV Part 2A) This brochure provides information about the qualifications and business practices of Craft & Sage Wealth, LLC (“Craft & Sage Wealth” or “C&S Wealth”). If you have any questions about the contents of this brochure, please contact us at the phone number listed above. 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. Registration (e.g. “registered investment advisor”) does not imply a certain level of skill or training. Additional information about Craft & Sage Wealth also is available on the SEC’s website at www.adviserinfo.sec.gov (CRD: 323565). Page 1 of 24  Craft & Sage Wealth Item 2: Material Changes This Brochure dated October 1, 2025, represents an amendment to the Brochure for Craft & Sage Wealth, LLC. Since the filing of the annual update Brochure on March 31, 2025, subsequently amended June 25, 2025, July 03, 2025, July 21, 2025, and August 28, 2025, we have changed our primary office address, have added details about a new affiliated entity and have updated detail regarding our custody practices. We have also made minor updates but no other material changes were made. Pursuant to SEC Rules, we will deliver to you a summary of any material changes to this and subsequent Brochures within 120 days of the close of our fiscal year. We may further provide other ongoing disclosure information about material changes as necessary. All such information will be provided to you free of charge. Currently, our Brochure may be requested by contacting us at (816) 436-9939. Additional information about the firm is also available via the SEC’s web site www.adviserinfo.sec.gov. The SEC’s web site also provides information about any persons affiliated with the firm who are registered as investment adviser representatives of the firm. Page 2 of 24  Craft & Sage Wealth 1 2 3 4 6 8 9 9 15 15 16 17 19 20 20 21 21 21 Item 3 Table of Contents Item 1: Firm Brochure (Form ADV Part 2A) Item 2: Material Changes Item 3 Table of Contents Item 4 Advisory Business Item 5 Fees and Compensation Item 6 Performance-Based Fees and Side-By-Side Management Item 7 Types of Clients Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Item 9 Disciplinary Information Item 10 Other Financial Industry Activities and Affiliations Item 11 Code of Ethics, Conflicts of Interest, and Personal Trading Item 12 Brokerage Practices Item 13 Review of Accounts Item 14 Client Referrals and Other Compensation Item 15 Custody Item 16 Investment Discretion Item 17 Voting Client Securities Item 18 Financial Information Page 3 of 24  Craft & Sage Wealth Item 4 Advisory Business Firm Description Craft & Sage Wealth, LLC (“C&S Wealth” or the “Firm”) is an SEC registered investment advisor. The legal entity is a Missouri limited liability company and was originally known as John T. Christy Financial Services, LLC when it was founded on June 14th, 2012. The firm has conducted business under the name “C&S Wealth”. The Principal Owner and Chief Compliance Officer of C&S Wealth is John T. Christy. Megan Brenner is a minority owner and control person of C&S Wealth. Types of Advisory Services The Firm offers a large variety of services, including portfolio management, investment analysis and financial planning for individuals and high net worth individuals, as well as businesses and charitable organizations. The Firm offers these services to clients or potential clients (“clients”). Investment Advisory Services C&S Wealth specializes in quantitative, fundamental, technical, and economic analysis to determine what investments are in favor of C&S Wealth’s investment models. C&S Wealth assesses clients’ current holdings and ensures alignment with both short- and long-term goals. The Firm performs ongoing reviews of investment performance and portfolio exposure to market conditions. Accordingly, the Firm is authorized to perform various functions without further approval from the client, such as the determination of securities to be purchased or sold without prior permission from the client for each transaction. Any and all trades are made in the best interest of the client as part of C&S Wealth’s fiduciary duty. However, risk is inherent to any investing strategy and model. Therefore, C&S Wealth does not guarantee any results or returns. Prior to engaging C&S Wealth to provide any investment advisory services, C&S Wealth requires a written financial service agreement (“FSA”) signed by the client prior to the engagement of any services. The FSA will outline services to which the client is entitled and fees the client will incur. C&S Wealth is an asset-based fee investment management firm. The firm does not receive commissions for purchasing or selling stocks, bonds, mutual funds, real estate investment trusts, or other commissioned products for clients. The firm is not affiliated with entities that sell financial products or securities. No investment commissions in any form are accepted. C&S Wealth does not act as a custodian of client assets. The client always maintains asset control. C&S Wealth places trades for clients under a limited power of attorney through qualified custodian/broker. Page 4 of 24  Craft & Sage Wealth Investment Discretion When you engage us for portfolio management services, you will be required to grant C&S Wealth the discretionary authority to implement its investment recommendations directly within your investment accounts held at the custodian without obtaining your specific consent prior to each transaction. This authority will include the ability to engage and terminate third-party managers (“TPMs”) to manage all or a portion of your account, and to determine the allocation of assets between and among such TPMs within the pre-determined asset allocation ranges for your account(s). Some of these TPMs specialize in Environmental, Social, and Governance-conscious model portfolios. The particulars of these will be disclosed in each TPM’s brochure. Financial Planning Financial plans and financial planning may include but are not limited to advice with respect to some or all the following financial topics: retirement income, risk management, tax reduction strategies, and investment strategies. Our financial planning advice will be delivered to you in the form or a written financial plan, a shorter report or checklist, or via informal discussions with you (in-person, via telephone or tele-video conference, or via e-mail), as we may agree in a written financial planning agreement. Some clients only wish to engage us in financial planning. In this scenario, the client retains the sole discretion to accept or reject any of our financial planning advice, in whole or in part, and is responsible for implementation and monitoring of all investments held away from the accounts designated for our investment advisory services. Services Tailored to Clients’ Needs Services are provided based on a client’s specific needs within the scope of the services provided as discussed above. A review of the information provided by the client regarding the client’s current financial situation, goals, and risk tolerances will be performed and advice will be provided that is in line with available information. Because C&S Wealth is a registered investment adviser, we are required to meet certain fiduciary standards when providing investment advice to clients. Additionally, when we provide investment advice related to a retirement plan account or an individual retirement account, we are considered fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. As such, we are required to act in your best interest and not put our interest ahead of yours, even though our compensation creates some conflicts with your interests in that the more you have us manage, the more we can earn. Our clients, however, are under no obligation to use services recommended by our associated persons. Furthermore, we believe that our recommendations are in the best interests of our clients and are consistent with our clients’ needs. Page 5 of 24  Craft & Sage Wealth Wrap Fee Program versus Portfolio Management Program C&S Wealth does not sponsor a “wrap fee” program where investment management services and trading costs are both covered in a single “wrap” fee, although outside managers used by the firm may sponsor and offer such programs. Information about outside manager wrap programs is available in the applicable outside manager’s Form ADV Part 2 Disclosure Brochure which is available upon request. Depending on the volume of trading activity, clients should note that a wrap fee program may cost the client more than purchasing management services and trading separately. Clients should also note that advisers may have a financial incentive to recommend wrap fee programs and that wrap fee sponsors may have a financial incentive to trade an account less frequently. Assets Under Management As of December 31, 2024, Adviser has the following assets under management: Discretionary assets: Non-discretionary assets: $289,680,654 $0 Page 6 of 24  Craft & Sage Wealth Item 5 Fees and Compensation Fees and other charges Individually Managed Accounts: Fees for individually managed accounts are tier priced as follows: Account Size Fee (Annual percentage)* First $500,000 Next $500, 000 Next $1,000,000 Next $1,000,000 Over $3,000,000 1.25% 1.10% 1.00% 0.90% 0.85% Individual representatives of C&S Wealth shall work with prospective clients to determine fees within the above fee schedule, and all fees are negotiable. All asset based fees are deducted by the qualified custodian of record on a quarterly basis in Advance, or as otherwise indicated in the client agreement. The quarterly fee shall be evaluated based on the value of the assets in the managed account on the last business day of the previous quarter. Fee adjustments may be made for cash flows depending on the type of account, the type of cash flow, the size of the cash flow, the platform used, etc. Any necessary refunds due to incomplete quarters upon engagement and/or termination shall be calculated as pro-rated for the amount of days in the quarter. Client statements for prior deductions will be provided on a quarterly basis. You will separately pay the selected TPMs and platforms a fee for their asset management services (a “TPM Fee”). C&S Wealth does not share in the TPM Fees paid to any TPM. The specific annual asset-based fee we will charge you is determined based on the number of TPMs utilized, the amount of their TPM Fees, and the overall complexity of monitoring your account. The specific TPM Fees charged by each TPM will be set forth in their Form ADV Part 2A (or disclosure brochure containing the equivalent information) and/or within your advisory agreement with C&S Wealth and/or your agreement with the particular TPM. TPMs will typically directly deduct their TPM Fees from the client’s account held at the custodian. In some instances, TPM Fees are separate and distinct from C&S Wealth’s advisory fees. All fees paid to Adviser for investment advisory services are separate and distinct from the expenses charged by third-party managers and Investment Companies to their shareholders. These fees and expenses are described to the client in separate disclosures. These fees will generally include third- party management fees, an Investment Company management fee, other fund expenses, and in some situations a possible distribution fee. Adviser will provide investment advisory services and portfolio management services but will not provide custodial or other administrative services. At no time will Adviser accept or maintain custody of a client’s funds or securities except for authorized fee deduction. The Client may contact the Custodian directly for disbursements, or account record changes, and may also do so in writing to the Page 7 of 24  Craft & Sage Wealth custodian. Adviser may act at the client’s convenience to facilitate such written communications to the Custodian, provided that such action is not construed to be custody of client assets. Client is responsible for all custodial and securities execution fees charged by the custodian and executing broker-dealer. Fees paid to Adviser are separate and distinct from the custodian and execution fees. Clients may request to terminate their advisory contract with Adviser, in whole or in part, by providing advance written notice. Upon termination, any fees paid in advance will be prorated to the date of termination and any excess will be refunded to the client through the Custodian. Client’s advisory agreement with the Advisor is non-transferable without Client’s written approval. Fee Deduction Disclosure The custodian sends the client a statement, at least quarterly, indicating the amount of our fees and all amounts disbursed from the account to our firm for our management fees. We have internal controls that seek to verify that the custodian is withdrawing fees accurately in accordance with your agreement, however, we strongly encourage clients independently verify the accuracy of the fee calculation, as the custodian will not verify the calculation. If a client does not have sufficient cash in the account(s) to cover the payment of fees, some or all of the securities held by the client will be liquidated in order to pay the fees. The custodian is responsible for sending the client account statements, clients will not receive an account statement or a fee invoice from us. Asset-based fees are always subject to the management agreement between the client and our firm, and we generally retain the right to amend our fee schedule with 30 days prior written notice to the client. Fixed Fees Fixed fees are commensurate with asset based fees and may be negotiated for investment services, and are established as fixed fees where the intent of the client is that fees are not variable automatically with changes in asset values on a quarterly basis. Fixed fee arrangements under the client agreement are for a period of one year, and then convert automatically to asset based fees unless a new fixed fee agreement is established. Fixed fees are deducted and invoiced in the same fashion as asset based fees for investment services. All fixed fees for services offered by the firm will be determined in advance based on the agreement between the client and the firm and based on the information provided by the client at that time. Fixed fees paid in advance will be prorated to the date of termination and the excess refunded to the client by check as soon as practicable. Where the firm may request a fee in advance, the amount paid in advance will not be more than $1,200 per client and 6 months in advance. The remaining fixed fees will be paid after services are performed. Page 8 of 24  Craft & Sage Wealth Right of Cancellation In addition to the right to terminate an agreement pursuant to its terms, a client may cancel an agreement with Adviser within five (5) business days of first receiving a copy of this disclosure brochure and supplement without penalty or fee. Client Responsibility for Third-Party Fees Clients may incur certain fees or charges imposed by third-parties other than Adviser in connection with investments or recommendations made by the Firm. We do not receive any portion of these fees. These fees and charges are separate and distinct from the fees or charges stated above and may include, but not be limited to: brokerage and transactions fees, mutual fund 12b-1 fees, certain deferred sales charges on previously purchased mutual funds transferred into the account, other transaction related fees, IRA and Qualified Retirement Plan fees, interest charged on margin borrowing, bank service fees, interest charged on debit balanced, “spreads” imposed by brokers and dealers representing implicit transaction costs, commissions and transfer taxes. Information regarding fees or charges assessed by any mutual funds held in client accounts is available in the appropriate prospectus. The firm is not responsible for, and does not receive any portion of, the fees imposed by such third parties. Please note, such fees will differ from client to client based on their own unique situation and selection of products and services. Financial Planning Fees Hourly or project-based fees are charged for those that wish to engage in a planning arrangement. The fee is negotiable, but in no event will exceed $500 per hour, or $5,000 per plan, contingent upon how many times Adviser and Client meet per year and complexity of the plan. Clients may terminate their planning agreement without penalty, for a full refund of C&S Wealth’s fees, within five business days of signing the Financial Planning Agreement. Thereafter, clients may terminate the Financial Planning Agreement generally upon written notice. Upon termination, any unearned fee will be refunded to the client. Prepayment of Fees Adviser's Investment management fees are payable quarterly in advance, based on the value of the account on the last business day of the previous quarter, with adjustments for additional deposits of funds if any made in a quarter already billed, which will be billed in arrears at the beginning of the next quarter for the additional cash flow. Upon termination, any fees paid in advance will be prorated to the date of termination and any excess will be refunded to client by check issued to the customer as soon as practicable, but no later than thirty (30) days after notice of termination. Fixed fees that are collected in advance will be refunded based on the prorated amount of work completed at the point of termination. Page 9 of 24  Craft & Sage Wealth Item 6 Performance-Based Fees and Side-By-Side Management C&S Wealth does not charge or accept performance-based fees. Item 7 Types of Clients C&S Wealth provides investment advice to many different types of clients. These clients generally include individuals, trusts, estates, corporations, and other types of business entities. Minimum Account Size The Firm does not require a minimum account size. Third-party managed programs generally have account minimum requirements, and these minimum requirements vary from manager to manager. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis The Firm may use the following methods when considering investment strategies and recommendations. Charting Review Charting is a technical analysis that charts the patterns of stocks, bonds, and commodities to help determine buy and sell recommendations for clients. It is a way of gathering and processing price and volume information in a security by applying mathematical equations and plotting the resulting data onto graphs in order to predict future price movements. A graphical historical record assists the analyst in spotting the effect of key events on a security’s price, its performance over a period of time, and whether it is trading near its high, near its low or in between. Chartists believe that recurring patterns of trading, commonly referred to as indicators, can help them forecast future price movements. Value Driven Equity Valuation: Proprietary modeling and evaluation performed designed to identify implied value in stocks. This includes an analysis of ratios, financial statements, management, insider trades and research with investor relations of various companies. Third Party Evaluation: Ongoing research on allocations, trends, performance, management and expenses of third party money managers. This includes strategic versus tactical approaches and looking across multiple asset classes to include stocks, bonds, fixed income, alternatives and managed future. Page 10 of 24  Craft & Sage Wealth Real Estate Analysis: Serving intentional and unintentional real estate investors and clients who are solely active investment real estate managers, others solely passive real estate investors and others using a combination of passive and active managers. This can include analysis of publicly traded real estate investments, Regulation D Private Placements and privately held investment real estate. Fundamental Review A fundamental analysis is a method of evaluating a company or security by attempting to measure its intrinsic value. Fundamental analysis attempts to determine the true value of a company or security by looking at all aspects of the company or security, including both tangible factors (e.g., machinery, buildings, land, etc.) and intangible factors (e.g., patents, trademarks, “brand” names, etc.). Fundamental analysis also involves examining related economic factors (e.g., overall economy and industry conditions, etc.), financial factors (e.g., company debt, interest rates, management salaries and bonuses, etc.), qualitative factors (e.g., management expertise, industry cycles, labor relations, etc.), and quantitative factors (e.g., debt-to-equity and price-to-equity ratios). The end goal of performing fundamental analysis is to produce a value that an investor can compare with the security's current price with the aim of determining what sort of position to take with that security (e.g., if underpriced, the security should be bought; if overpriced the security should sold). Fundamental analysis uses real data to evaluate a security's value. Although most analysts use fundamental analysis to value stocks, this method of valuation can be used for many types of securities. Technical Review A technical analysis is a method of evaluating securities that analyzes statistics generated by market activity, such as past prices and volume. Technical analysis does not attempt to measure a security's intrinsic value, but instead uses past market data and statistical tools to identify patterns that can suggest future activity. Historical performance of securities and the markets can indicate future performance. Cyclical Review A cyclical analysis assumes the market reacts in reoccurring patterns that can be identified and leveraged to provide performance. Cyclical analysis of economic cycles is used to determine how these reoccurring patterns, or cycles, affect the returns of a given investment, asset, or company. Cyclical analysis is a time-based assessment which incorporates past and present performance to determine future value. Cyclical analyses exist because the broad economy has been shown to move in cycles, from periods of peak performance to periods of low performance. The risks of this strategy are two-fold: (1) the markets do not always repeat cyclical patterns; and (2) if too many investors begin to implement this strategy, it changes the very cycles of which they are trying to take advantage. Economic Review An economic analysis determines the economic environment over a certain time horizon. This involves following and updating historic economic data such as U.S. gross domestic product Page 11 of 24  Craft & Sage Wealth and consumer price index as well as monitoring key economic drivers such as employment, inflation, and money supply for the world’s major economies. B. Investment Strategies When implementing investment advice to clients, the Firm may employ a variety of strategies to best pursue the objects of clients. Depending on market trends and conditions, C&S Wealth will employee any technique or strategy herein described, at the Firm’s discretion and in the best interests of the client. The Firm does not recommend any particular security or type of security. Instead, the Firm makes recommendations to meet a particular client’s financial objectives. There is inherent risk to any investment and clients may suffer loss of ALL OR PART of a principal investment. Long-Term Purchases Long-term purchases are securities that are purchased with the expectation that the value of those securities will grow over a relatively long period, generally greater than one year. Long-term purchases may be affected by unforeseen changes in the company in which a client is invested or in the overall market. Long term trading is designed to capture market rates of both return and risk. Frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Due to its nature, the long-term strategy can expose clients to various other types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include, but are not limited to, inflation (purchasing power) risk, interest rate risk, economic risk, and political/regulatory risk. Short-Term Purchases Short-term purchases are securities that are purchased with the expectation that they will be sold within a relatively short period of time, generally less than one year, to take advantage of the securities’ short-term price fluctuations. Short-term trading generally holds greater risk. Frequent trading can affect investment performance due to increased brokerage fees and other transaction costs and taxes. Strategic Asset Allocation Asset allocation is a combination of several different types of investments; typically, this includes stocks, bonds, and cash equivalents among various asset classes to achieve diversification. The objective of asset allocation is to manage risk and market exposure while still positioning a portfolio to meet financial objectives. C. Risk of Loss Investing inherently involves risk up to and including loss of the principal sum. Further, past performance of any security is not necessarily indicative of future results. Therefore, future performance of any specific investment or investment strategy based on past performance should not be assumed as a guarantee. C&S Wealth does not provide any representation or guarantee that the financial goals of clients will be achieved. Page 12 of 24  Craft & Sage Wealth The potential return or gain and potential risk or loss of an investment varies, generally speaking, with the type of product invested in. Below is an overview of the types of products available on the market and the associated risks of each: General Risks. Investing in securities always involves risk of loss that you should be prepared to bear. We do not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. We cannot offer any guarantees or promises that your financial goals and objectives can or will be met. Past performance is in no way an indication of future performance. We also cannot assure that third parties will satisfy their obligations in a timely manner or perform as expected or marketed. General Market Risk. Investment returns will fluctuate based upon changes in the value of the portfolio securities. Certain securities held may be worth less than the price originally paid for them, or less than they were worth at an earlier time. Common Stocks. Investments in common stocks, both directly and indirectly through investment in shares of ETFs, may fluctuate in value in response to many factors, including, but not limited to, the activities of the individual companies, general market and economic conditions, interest rates, and specific industry changes. Such price fluctuations subject certain strategies to potential losses. During temporary or extended bear markets, the value of common stocks will decline, which could also result in losses for each strategy. Portfolio Turnover Risk. High rates of portfolio turnover could lower performance of an investment strategy due to increased costs and may result in the realization of capital gains. If an investment strategy realizes capital gains when it sells its portfolio investments, it will increase taxable distributions to you. High rates of portfolio turnover in a given year would likely result in short-term capital gains and under current tax law you would be taxed on short-term capital gains at ordinary income tax rates, if held in a taxable account. Non-Diversified Strategy Risk. Some investment strategies may be non-diversified (e.g., investing a greater percentage of portfolio assets in a particular issuer and owning fewer securities than a diversified strategy). Accordingly, each such strategy is subject to the risk that a large loss in an individual issuer will cause a greater loss than it would if the strategy held a larger number of securities or smaller positions sizes. Model Risk. Financial and economic data series are subject to regime shifts, meaning past information may lack value under future market conditions. Models are based upon assumptions that may prove invalid or incorrect under many market environments. We may use certain model outputs to help identify market opportunities and/or to make certain asset allocation decisions. There is no guarantee any model will work under all market conditions. For this reason, we include model related results as part of our investment decision process but we often weigh professional judgment more heavily in making trades or asset allocations. ETF Risks, including Net Asset Valuations and Tracking Error. An ETF's performance may not exactly match the performance of the index or market benchmark that the ETF is designed to track because 1) the ETF will incur expenses and transaction costs not incurred by any applicable index or market benchmark; 2) certain securities comprising the index or market benchmark tracked by the ETF Page 13 of 24  Craft & Sage Wealth may, from time to time, temporarily be unavailable; and 3) supply and demand in the market for either the ETF and/or for the securities held by the ETF may cause the ETF shares to trade at a premium or discount to the actual net asset value of the securities owned by the ETF. Certain ETF strategies may from time to time include the purchase of fixed income, commodities, foreign securities, American Depository Receipts, or other securities for which expenses and commission rates could be higher than normally charged for exchange-traded equity securities, and for which market quotations or valuation may be limited or inaccurate. Clients should be aware that to the extent they invest in ETF securities they will pay two levels of advisory compensation – advisory fees charged by Adviser plus any advisory fees charged by the issuer of the ETF. This scenario may cause a higher advisory cost (and potentially lower investment returns) than if a Client purchased the ETF directly. An ETF typically includes embedded expenses that may reduce the ETF's net asset value, and therefore directly affect the ETF's performance and indirectly affect a Client’s portfolio performance or an index benchmark comparison. Expenses of the ETF may include investment advisor management fees, custodian fees, brokerage commissions, and legal and accounting fees. ETF expenses may change from time to time at the sole discretion of the ETF issuer. ETF tracking error and expenses may vary. Inflation, Currency, and Interest Rate Risks. Security prices and portfolio returns will likely vary in response to changes in inflation and interest rates. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of an investor’s future interest payments and principal. Inflation also generally leads to higher interest rates, which in turn may cause the value of many types of fixed income investments to decline. In addition, the relative value of the U.S. dollar-denominated assets primarily managed by Adviser may be affected by the risk that currency devaluations affect Client purchasing power. Liquidity Risk. Liquidity is the ability to readily convert an investment into cash to prevent a loss, realize an anticipated profit, or otherwise transfer funds out of the particular investment. Generally, investments are more liquid if the investment has an established market of purchasers and sellers, such as a stock or bond listed on a national securities exchange. Conversely, investments that do not have an established market of purchasers and sellers may be considered illiquid. Your investment in illiquid investments may be for an indefinite time, because of the lack of purchasers willing to convert your investment to cash or other assets. Legislative and Tax Risk. Performance may directly or indirectly be affected by government legislation or regulation, which may include, but is not limited to: changes in investment advisor or securities trading regulation; change in the U.S. government’s guarantee of ultimate payment of principal and interest on certain government securities; and changes in the tax code that could affect interest income, income characterization and/or tax reporting obligations, particularly for options, swaps, master limited partnerships, Real Estate Investment Trust, Exchange Traded Products/Funds/Securities. We do not engage in tax planning, and in certain circumstances a Client may incur taxable income on their investments without a cash distribution to pay the tax due. Clients and their personal tax advisors are responsible for how the transactions in their account are reported to the IRS or any other taxing authority. Foreign Investing and Emerging Markets Risk. Foreign investing involves risks not typically associated with U.S. investments, and the risks maybe exacerbated further in emerging market Page 14 of 24  Craft & Sage Wealth countries. These risks may include, among others, adverse fluctuations in foreign currency values, as well as adverse political, social, and economic developments affecting one or more foreign countries. In addition, foreign investing may involve less publicly available information and more volatile or less liquid securities markets, particularly in markets that trade a small number of securities, have unstable governments, or involve limited industry. Investments in foreign countries could be affected by factors not present in the U.S., such as restrictions on receiving the investment proceeds from a foreign country, foreign tax laws or tax withholding requirements, unique trade clearance or settlement procedures, and potential difficulties in enforcing contractual obligations or other legal rules that jeopardize shareholder protection. Foreign accounting may be less transparent than U.S. accounting practices and foreign regulation may be inadequate or irregular. Information Security Risk. We may be susceptible to risks to the confidentiality and security of its operations and proprietary and customer information. Information risks, including theft or corruption of electronically stored data, denial of service attacks on our website or websites of our third-party service providers, and the unauthorized release of confidential information are a few of the more common risks faced by us and other investment advisers. Data security breaches of our electronic data infrastructure could have the effect of disrupting our operations and compromising our customers' confidential and personally identifiable information. Such breaches could result in an inability of us to conduct business, potential losses, including identity theft and theft of investment funds from customers, and other adverse consequences to customers. We have taken and will continue to take steps to detect and limit the risks associated with these threats. Tax Risks. Tax laws and regulations applicable to an account with Adviser may be subject to change and unanticipated tax liabilities may be incurred by an investor as a result of such changes. In addition, customers may experience adverse tax consequences from the early assignment of options purchased for a customer's account. Customers should consult their own tax advisers and counsel to determine the potential tax-related consequences of investing. Advisory Risk. There is no guarantee that our judgment or investment decisions on behalf of particular any account will necessarily produce the intended results. Our judgment may prove to be incorrect, and an account might not achieve her investment objectives. In addition, it is possible that we may experience computer equipment failure, loss of internet access, viruses, or other events that may impair access to accounts’ custodians’ software. Adviser and its representatives are not responsible to any account for losses unless caused by Adviser breaching our fiduciary duty. TPM Risks. A TPM’s past track record of success cannot be relied upon as a predictor of success in the future. In addition, the underlying holdings of your TPM account(s) are determined by TPM directly, and may change overtime without advance warning to C&S Wealth, creating the potential for overlap with other investments held in your account. This increase in the correlation of your holdings will increase the risk of loss where the value of any overlapping holdings should decrease. There is also a risk that a TPM may deviate from the stated investment mandate or strategy of the account, which could make the holding(s) less suitable for the client’s portfolio. C&S Wealth does not control any TPM’s daily business and compliance operations, and thus our firm may be unaware of any lack of internal controls necessary to prevent business, regulatory or reputational deficiencies. Page 15 of 24  Craft & Sage Wealth Dependence on Key Employees. An accounts success depends, in part, upon the ability of our key professionals to achieve the targeted investment goals. The loss of any of these key personnel could adversely impact the ability to achieve such investment goals and objectives of the account. Adviser does not primarily recommend a particular type of security. Item 9 Disciplinary Information Registered investment advisers are required to disclose any legal or disciplinary events that are material to a client’s or prospective client’s evaluation of the advisory business or integrity of the Firm’s management. C&S Wealth has no disciplinary disclosures. John Christy and Megan Brenner, the owners and operators of C&S Wealth, have no disciplinary disclosures. Item 10 Other Financial Industry Activities and Affiliations Certain representatives of C&S Wealth are licensed insurance agents of our affiliated insurance agency, Craft & Sage Risk Management, LLC. From time to time, they will offer clients insurance related advice and or products. Clients should be aware that these services pay a commission and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. C&S Wealth is required to always act in the best interest of the client, including when proposing the sale of commissionable products to advisory clients. However, clients always have the right to decide whether or not to purchase insurance product and whether or not to utilize the services of any representative of C&S Wealth in such individual’s outside capacity. Certain representatives of C&S Wealth are also agents of another affiliated entity, Craft & Sage Real Estate, LLC (C&S Real Estate). As a service to clients who are interested in investing in privately held investments, C&S Real Estate helps facilitate a relationship with Insight Investment Advisers, LLC as a solicitor for Insight Investment Advisers, LLC. Should Clients referred by C&S Real Estate choose to engage Insight Investment Advisers, LLC for their services, C&S Real Estate receives a portion of the fee paid to Insight Investment Advisers, LLC. Clients should be aware that referral fees paid to C&S Real Estate by Insight Investment Advisers, LLC provides C&S Real Estate and C&S Wealth a financial incentive to recommend the use of Insight Investment Advisers, LLC. The referral fee paid to C&S Real Estate however does not affect the fee paid by Client. Clients are encouraged to do their own due diligence and they are required to sign a fee disclosure with Insight Investment Advisers, LLC on how C&S Wealth’s affiliate, C&S Real Estate, is compensated. This fee disclosure outlines the arrangement with Insight Investment Advisers, LLC. C&S Wealth has also entered into an agreement with Mutual Securities Inc., member FINRA/SIPC, whereby Mutual Securities will provide operational support services as a platform provider of clients directly held investments. These holdings might include variable annuities, among others. This contractual engagement does not include exercising discretionary authority over Mutual Securities, Inc. brokerage accounts or directly held investments, although we do provide limited monitoring of certain directly held investments. Clients may be solicited to utilize Mutual Securities but are under no obligation to move their variable annuities or other securities. For clients of Mutual Securities who provide Mutual Securities with written consent requesting ongoing investment advisory services, our firm will be engaged to provide ongoing investment-related advisory services on a non-discretionary Page 16 of 24  Craft & Sage Wealth basis to Mutual Securities which may include a general review of client investment holdings, general investment advice, and specific securities recommendations on certain directly held investment holdings. For our advisory services provided to Mutual Securities, our firm is compensated by Mutual Securities through a percentage of the overall assets under advisement. Clients should be aware that the receipt of these advisory revenues creates a conflict of interest for us as it creates another incentive for us to recommend the use of Mutual Securities. We address these conflicts of interest by (1) providing disclosure of the relationship and the associated conflicts of interest to clients in this Form ADV Part 2A Brochure, and (2) reminding clients that they are under no obligation to use Mutual Securities. Item 11 Code of Ethics, Conflicts of Interest, and Personal Trading A. Fiduciary Status An investment advisor is considered a fiduciary. As a fiduciary, it is an investment advisor’s responsibility to provide fair and full disclosure of all material facts. In addition, an investment advisor has a duty of utmost good faith to act solely in the best interest of each of its clients. C&S Wealth and its representatives have a fiduciary duty to all clients. C&S Wealth and its representatives’ fiduciary duty to clients is considered the core underlying principle for C&S Wealth’s Code of Ethics and represents the expected basis for all representatives’ dealings with clients. C&S Wealth has the responsibility to ensure that the interests of clients are placed ahead of it or its representatives’ own investment interest. All representatives will conduct business in an honest, ethical, and fair manner. All representatives will comply with all federal and state securities laws at all times. Full disclosure of all material facts and potential conflicts of interest will be provided to clients prior to services being conducted. All representatives have a responsibility to avoid circumstances that might negatively affect or appear to affect the representatives’ duty of complete loyalty to their clients. B. Investment Recommendations Involving a Material Financial Interest and Conflict of Interest C&S Wealth does not recommend that clients buy or sell any security in which a related person to their firm. Retirement Plan Rollovers: A client or prospective client leaving an employer has several options for the company retirement plan, which may include leaving the assets in the plan, moving to another employer’s plan, moving the assets to an Individual Retirement Account (IRA), or withdrawing the assets altogether (which could have adverse tax consequences). C&S Wealth reviews all these options with the client or prospective client including the costs and administrative and investment impact of each. If C&S Wealth recommends that the client roll over the retirement plan assets into an account managed by C&S Wealth, such a recommendation creates a conflict of interest if C&S Wealth will earn additional fees on the rolled over assets. No client is under any obligation to roll over any retirement plan assets to an account managed by C&S Wealth. Page 17 of 24  Craft & Sage Wealth C. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest Adviser and/or its investment advisory representatives may from time-to-time purchase or sell products or investments that they may recommend to clients. Adviser has adopted a Code of Ethics that sets forth the basic policies of ethical conduct for all managers, officers, and employees of the adviser. In addition, the Code of Ethics governs personal trading by each employee of Adviser deemed to be an Access Person and is intended to ensure that securities transactions effected by Access Persons of Adviser are conducted in a manner that avoids any actual or potential conflict of interest between such persons and clients of the adviser or its affiliates. Adviser collects and maintains records of securities holdings and securities transactions effected by Access Persons. These records are reviewed to identify and resolve potential conflicts of interest. Adviser’s Code of Ethics is available upon request. D. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest C&S Wealth does not maintain a firm proprietary trading account and does not have a material financial interest in any securities being recommended and therefore no conflicts of interest exist. However, employees may buy or sell securities at the same time they buy or sell securities for clients. In order to mitigate conflicts of interest such as front running, employees are required to disclose all reportable securities transactions as well as provide C&S Wealth with copies of their brokerage statements. The Chief Compliance Officer of C&S Wealth is John Christy. John or a delegate will review all employee trades each quarter. The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the firm receive preferential treatment over employee transactions. Page 18 of 24  Craft & Sage Wealth Item 12 Brokerage Practices A. Selection and Recommendation C&S Wealth has a duty to select brokers, dealers and other trading venues that provide best execution for clients. The duty of best execution requires an investment adviser to seek to execute securities transactions for clients in such a manner that the client’s total cost or proceeds in each transaction is the most favorable under the circumstances, taking into account all relevant factors. The lowest possible commission, while very important, is not the only consideration. The brokers dealers C&S Wealth currently utilizes are Asset Mark and Charles Schwab. It is the policy of the Firm to seek best execution in all portfolio trading activities for all investment disciplines and products, regardless of whether commissions are charged. This applies to trading in any instrument, security, or contract including equities, bonds, and forward or derivative contracts. The standards and procedures governing best execution are set forth in several written policies. Generally, to achieve best execution, C&S Wealth considers the following factors, without limitation, in selecting brokers and intermediaries: ⋅ Execution capability; ⋅ Confidentiality; ⋅ Order size and market depth; ⋅ Reputation and integrity; ⋅ Availability of competing markets and ⋅ Responsiveness; liquidity; ⋅ Trading characteristics of the security; ⋅ Recordkeeping; ⋅ Availability of accurate information ⋅ Ability and willingness to commit comparing markets; capital; ⋅ Available technology; and ⋅ Quantity and quality of research received from the broker dealer; ⋅ Ability to address current market ⋅ Financial responsibility of the conditions. broker-dealer; Page 19 of 24  Craft & Sage Wealth B. Research and Other Soft Dollar Benefits Soft dollar practices are arrangements whereby an investment adviser directs transactions to a broker‐ dealer in exchange for certain products and services that are allowable under SEC and STATE rules. Client commissions may be used to pay for brokerage and research services and products as long as they are eligible under Section 28(e) of the Exchange Act of 1934. Section 28(e) sets forth a “safe harbor,” which provides that an investment adviser that has discretion over a client account is not in breach of its fiduciary duty when paying more than the lowest commission rate available if the adviser determines in good faith that the rate paid is commensurate with the value of brokerage and research services provided by the broker‐dealer. C&S Wealth does not currently have any soft dollar benefit arrangements. C. Brokerage for Client Referrals C&S Wealth does not receive client referrals from third parties for recommending the use of specific broker-dealer brokerage services. D. Directed Brokerage Securities transactions are executed by brokers selected by C&S Wealth. C&S Wealth will not accept directed brokerage outside of C&S Wealth’s own selected custodian. E. Order Aggregation C&S Wealth may, at times, aggregate sale and purchase orders of securities (“block trading”) for advisory accounts with similar orders in order to obtain the best pricing averages and minimize trading costs. This practice is reasonably likely to result in administrative convenience or an overall economic benefit to the client. Clients also benefit relatively from better purchase or sale execution prices, or beneficial timing of transactions or a combination of these and other factors. Aggregate orders will be allocated to client accounts in a systematic non-preferential manner. C&S Wealth may aggregate or “bunch” transactions for a client’s account with those of other clients in an effort to obtain the best execution under the circumstances. F. Trade Error Policy C&S Wealth maintains a record of any trading errors that occur in connection with investment activities of its clients. Both gains and losses that result from a trading error made by C&S Wealth will be borne or realized by C&S Wealth. Item 13 Review of Accounts A. Periodic Reviews The Firm regularly reviews and evaluates client accounts for compliance with each client’s investment objectives, policies, and restrictions. The Firm analyzes rates of return and allocation of assets to determine model strategy effectiveness. Such reviews are conducted by the Chief Compliance Officer or delegate of C&S Wealth and shall occur at least once per calendar year. Page 20 of 24  Craft & Sage Wealth B. Intermittent Review Factors Intermittent reviews may be triggered by substantial market fluctuation, economic or political events, or changes in the client’s financial status (such as retirement, termination of employment, relocation, inheritance, etc.). Clients are advised to notify C&S Wealth promptly if there are any material changes in their financial situation, investment objectives, or in the event they wish to place restrictions on their account. Page 21 of 24  Craft & Sage Wealth C. Reports Clients may receive confirmations of purchases and sales in their accounts and will receive, at least quarterly, statements containing account information such as account value, transactions, and other relevant information. Confirmations and statements are prepared and delivered by the custodian. D. Financial Plans All financial planning accounts are reviewed upon financial plan creation and plan delivery by a qualified professional. There are multiple levels of review for each financial plan. Each financial planning client will receive the financial plan upon completion. Item 14 Client Referrals and Other Compensation A. Client Referrals Clients may be introduced to C&S Wealth by other third parties. In the event that C&S Wealth compensates any outside party for the referral of a client to C&S Wealth, any such compensation will be paid by C&S Wealth, and not the client. If the client is introduced to C&S Wealth by an unaffiliated third party, information will be disclosed to the client that generally describes the referral arrangement with C&S Wealth, including the compensation for the referral, and the client will be provided with a copy of C&S Wealth’s ADV Part 2A and 2B. B. Other Compensation C&S Wealth occasionally receives compensation for referrals to certain outside parties. Clients should be aware that the receipt of referral compensation gives C&S Wealth a financial incentive to make certain recommendations. Clients are not however required to use any outside provider recommended by C&S Wealth. See Item 10 above for additional information about such referral arrangements. C&S Wealth also receives economic benefits from our custodian in the form of the support products and services that are made available to us and to other independent investment advisors. These products and services, how they benefit us, and the related conflicts of interest are described in Item 12 above. The firm may also on limited occasions receive travel expense reimbursements for industry meetings related to market analysis, investment strategies, and practice management. The availability to us of these economic benefits is not based on us giving particular investment advice, such as buying or recommending particular securities for our clients. Furthermore, our representatives are required to make all investment decisions and recommendations based solely on the interests of the applicable client Page 22 of 24  Craft & Sage Wealth Item 15 Custody As noted in Item 12, C&S Wealth recommends that clients’ assets be held by a qualified custodian. Although we do not hold assets, we do have custody due to our ability to direct the deduction of advisory fees from your account with your authorization and or to request disbursements to you or other parties on your behalf (although various types of written authorizations and internal controls are required by regulatory guidelines depending on the type of disbursements). You will receive account statement directly from your custodian at least quarterly, which will be sent to the email or postal mailing address you provide. C&S Wealth may also periodically provide performance reports. C&S Wealth urges clients to carefully review custodial statements and compare them to any account reports that we might provide. Item 16 Investment Discretion C&S Wealth may exercise full discretionary authority to supervise and direct the investments of a client’s account. This authority will be granted by clients upon completion of C&S Wealth’s FSA. This authority allows C&S Wealth and its affiliates to implement investment decisions without prior consultation with the client. Such investment decisions are made in the client’s best interest and in accordance with the client’s investment objectives. Other than agreed upon management fees due to C&S Wealth, this discretionary authority does not grant the Firm the authority to have custody of any assets in the client’s account or to direct the delivery of any securities or the payment of any funds held in the account to C&S Wealth. The discretionary authority granted by the client to the Firm does not allow C&S Wealth to direct the disposition of such securities or funds to anyone except the account holder. Item 17 Voting Client Securities The Firm does not perform proxy voting services on the client’s behalf. Clients are encouraged to read through the information provided with the proxy voting documents and to make a determination based on the information provided. Upon the client’s request, Firm representatives may provide limited clarifications of the issues presented in the proxy voting materials based on his or her understanding of issues presented in the proxy voting materials. However, clients have the ultimate responsibility for making all proxy voting decisions. Page 23 of 24  Craft & Sage Wealth Item 18 Financial Information A. Balance Sheet Requirement C&S Wealth is not the qualified custodian for client funds or securities and does not require prepayment of fees of more than $1200 per client, six (6) months or more in advance. B. Financial Condition C&S Wealth does not have any financial impairment that would preclude the Firm from meeting contractual commitments to clients. C. Bankruptcy Petition C&S Wealth has not been the subject of a bankruptcy petition at any time during the last 10 years. Page 24 of 24