DIASTOLE WEALTH MANAGEMENT, INC.

Item 1. Cover Page Form ADV Part 2A Last Updated: August 6, 2025 SEC File Number: 801-57610 Diastole Wealth Management, Inc. CRD Number: 111604 58 Boston Street Guilford, CT 06437 (203) 458-5220 www.dwinvest.com This brochure provides information about the qualifications and business practices of Diastole Wealth Management, Inc. (“DWM”). If you have any questions about the contents of this brochure, please contact Meredith Eden at (203) 458-5220 and/or via meden@dwinvest.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 DWM is also available on the SEC’s website at www.adviserinfo.sec.gov. Although DWM may use the term “registered investment adviser” or use the term “registered” through this Form ADV Part 2A, the use of these terms is not intended to imply a certain level of skill or training. Form ADV Part 2A/B Diastole Wealth Management, Inc. Page 1 of 33 ver. 1-08062025  Item 2. Material Changes since Last Update The U.S. Securities and Exchange Commission (“SEC”) issued a final rule requiring advisers to provide a Firm Brochure in narrative “plain English” format. The new final rule specifies mandatory sections and organization. All new investment advisers must comply with the Rule. Material Changes since last update on March 17, 2025: • Form ADV Part 2A. Meredith Eden was appointed as DWM’s Chief Compliance Officer (CCO) effective August 1, 2025. Throughout this Brochure, any reference to the designated CCO will refer to Meredith Eden. Annual Update The Material Changes section of this brochure will be updated annually and/or when material changes occur since the previous release of DWM’s Brochure. A summary of changes is necessary to inform clients of any substantive changes to DWM’s policies, practices, or conflicts of interests so that they can determine whether to review the brochure in its entirety or to contact DWM with questions about the changes. Full Brochure Available Clients who would like to receive a complete copy of our Firm Brochure, please contact us by telephone at (203) 458-5220 or visit our website at www.dwinvest.com. Form ADV Part 2A/B Diastole Wealth Management, Inc. Page 2 of 33 ver. 1-08062025  Item 3. Table of Contents Form ADV Part 2A ITEM 1. COVER PAGE ....................................................................................................................................... 1 ANNUAL UPDATE ........................................................................................................................................................... 2 FULL BROCHURE AVAILABLE ............................................................................................................................................. 2 ITEM 4. ADVISORY BUSINESS ........................................................................................................................ 6 PRINCIPAL OWNERS ....................................................................................................................................................... 6 TYPES OF ADVISORY SERVICES OFFERED ............................................................................................................................. 6 FINANCIAL PLANNING AND CONSULTING SERVICES ................................................................................................................ 6 PRIVATE INVESTMENT FUNDS ........................................................................................................................................... 7 SELECTION OF OTHER ADVISERS ........................................................................................................................................ 7 TYPES OF INVESTMENTS .................................................................................................................................................. 7 TERMINATION OF ACCOUNT ............................................................................................................................................. 8 WRAP FEE PROGRAM ..................................................................................................................................................... 8 IRA ROLLOVER RECOMMENDATIONS ................................................................................................................................. 8 DWM BENEFITS FINANCIALLY FROM THE ROLLOVER OF YOUR ASSETS FROM A RETIREMENT ACCOUNT TO AN ACCOUNT THAT WE MANAGE OR PROVIDE INVESTMENT ADVICE, BECAUSE THE ASSETS INCREASE OUR ASSETS UNDER MANAGEMENT AND, IN TURN, OUR ADVISORY FEES. AS A FIDUCIARY, WE ONLY RECOMMEND A ROLLOVER WHEN WE BELIEVE IT IS IN YOUR BEST INTEREST. .................................... 8 ASSETS UNDER MANAGEMENT ......................................................................................................................................... 8 ITEM 5. FEES AND COMPENSATION ............................................................................................................. 9 FEES FOR SELECTION OF OTHER ADVISERS ......................................................................................................................... 10 ADDITIONAL FEES AND EXPENSES .................................................................................................................................... 10 ITEM 6. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ...................................... 11 ITEM 7. TYPES OF CLIENTS .......................................................................................................................... 11 ITEM 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ........................ 11 METHODS OF ANALYSIS ................................................................................................................................................ 11 CASH MANAGEMENT .................................................................................................................................................... 12 TAX CONSIDERATIONS................................................................................................................................................... 13 ECONOMIC CONDITIONS................................................................................................................................................ 13 EQUITY RISKS .............................................................................................................................................................. 13 FIXED INCOME RISKS .................................................................................................................................................... 14 ETF RISKS .................................................................................................................................................................. 14 ITEM 9. DISCIPLINARY INFORMATION ....................................................................................................... 15 DISCLOSURE EVENTS..................................................................................................................................................... 15 ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS .......................................... 16 NORTHCREEK FUNDS .................................................................................................................................................... 17 INSURANCE PRODUCTS.................................................................................................................................................. 17 RECOMMENDATION OF OTHER ADVISERS .......................................................................................................................... 17 ITEM 11. CODE OF ETHICS, PARTICIPATION/INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ..................................................................................................................................... 18 CODE OF ETHICS .......................................................................................................................................................... 18 PARTICIPATION/INTEREST IN CLIENT TRANSACTIONS .......................................................................................... 18 PERSONAL TRADING PRACTICES....................................................................................................................................... 18 Form ADV Part 2A/B Diastole Wealth Management, Inc. Page 3 of 33 ver. 1-08062025  AGGREGATED TRADING ................................................................................................................................................. 18 ITEM 12. BROKERAGE PRACTICES ............................................................................................................ 19 RESEARCH AND OTHER SOFT DOLLAR BENEFITS ................................................................................................ 19 HOW WE SELECT CUSTODIANS/BROKERS ......................................................................................................................... 19 YOUR BROKERAGE AND CUSTODY COSTS .......................................................................................................................... 20 PRODUCTS AND SERVICES AVAILABLE TO US FROM SCHWAB ................................................................................................. 20 AGGREGATION OF CLIENT ORDERS .................................................................................................................................. 21 ITEM 13. REVIEW OF ACCOUNTS ................................................................................................................ 22 ITEM 14. CLIENT REFERRALS AND OTHER COMPENSATION .............................................................. 22 RECEIPT OF ECONOMIC BENEFIT (NON-CLIENT) .................................................................................................................. 22 CHARLES SCHWAB & CO., INC - INSTITUTIONAL .................................................................................................................. 22 DIRECT/INDIRECT COMPENSATION FOR CLIENT REFERRALS .................................................................................................. 23 ITEM 15. CUSTODY ......................................................................................................................................... 23 DEBIT FEES ................................................................................................................................................................. 23 PRIVATE FUNDS ........................................................................................................................................................... 23 WIRE TRANSFER AND/OR STANDING LETTER OF AUTHORIZATION ........................................................................................... 23 ITEM 16. INVESTMENT DISCRETION ........................................................................................................... 24 ITEM 17. VOTING CLIENT SECURITIES ....................................................................................................... 24 ITEM 18. FINANCIAL INFORMATION ............................................................................................................ 24 PRE-PAYMENT OF FEES ................................................................................................................................................. 24 MATERIAL IMPACT OF DISCRETIONARY AUTHORITY ............................................................................................................ 24 CUSTODY DISCLOSURE .................................................................................................................................................. 24 BANKRUPTCY DISCLOSURE ............................................................................................................................................. 25 PAYABLE NOTES ........................................................................................................................................................... 25 ADDITIONAL INFORMATION ......................................................................................................................... 25 TRADE ERRORS ............................................................................................................................................................ 25 CLASS ACTION LAWSUITS ............................................................................................................................................... 25 PRIVACY POLICY NOTICE................................................................................................................................................ 25 IRA ROLLOVER CONSIDERATIONS .................................................................................................................................... 26 ITEM 1. COVER PAGE ..................................................................................................................................... 28 ITEM 2. EDUCATIONAL BACKGROUND AND EXPERIENCE ................................................................... 29 SUPERVISED PERSONS ................................................................................................................................................... 29 ELIZABETH D. EDEN ...................................................................................................................................................... 29 ELIZABETH E. COOK ...................................................................................................................................................... 29 MARY L. O’TOOLE, CFA ............................................................................................................................................... 29 JENNIFER L. O’BRIEN .................................................................................................................................................... 30 ENIKO MIKLE .............................................................................................................................................................. 30 BARBARA A. BUZZELLI .................................................................................................................................................. 30 ETHAN EDEN ............................................................................................................................................................... 30 MERDITH EDEN ........................................................................................................................................................... 31 ITEM 3. DISCIPLINARY INFORMATION ....................................................................................................... 31 CRIMINAL OR CIVIL ACTION ........................................................................................................................................... 31 ADMINISTRATIVE PROCEEDING (SEC/FEDERAL/STATE) ....................................................................................................... 31 ADMINISTRATIVE PROCEEDING (SRO) ............................................................................................................................. 32 Form ADV Part 2A/B Diastole Wealth Management, Inc. Page 4 of 33 ver. 1-08062025  USE OF BROKERCHECK ......................................................................................................................................... 32 ITEM 4. OTHER BUSINESS ACTIVITIES ...................................................................................................... 32 OTHER RELATED INVESTMENT BUSINESS .......................................................................................................................... 32 NORTHCREEK FUNDS .................................................................................................................................................... 32 ITEM 5. ADDITIONAL COMPENSATION ....................................................................................................... 33 ITEM 6. SUPERVISION .................................................................................................................................... 33 DESIGNATED SUPERVISOR ..................................................................................................................................... 33 Form ADV Part 2A/B Diastole Wealth Management, Inc. Page 5 of 33 ver. 1-08062025  Item 4. Advisory Business Diastole Wealth Management, Inc. (“DWM”) has been a registered investment advisor since May 2000 providing discretionary and/or non-discretionary investment management services to high-net-worth individuals, individuals other than high net worth individuals, charitable organizations and pooled investment vehicles or private funds which are related private partnerships (herein referred to as “Client” or “Clients”). Principal Owners DWM is primarily owned by Elizabeth D. Eden, Elizabeth E. Cook, Ethan A. Eden, and Meredith P. Eden. DWM is not a publicly held company and no part of DWM is owned by an individual or company through any subsidiaries or “intermediate subsidiaries.” Types of Advisory Services Offered Investment Advisory Services We offer discretionary and non-discretionary portfolio management services. Our investment advice is tailored to meet our clients' needs and investment objectives. We consider financial planning and consulting an integral aspect of the portfolio management process designed to assist our clients in reaching their financial and retirement goals. If you retain our firm for portfolio management services, we will meet with you to determine your investment objectives, risk tolerance, and other relevant information at the beginning of our advisory relationship. We will use the information we gather to develop a strategy that enables our firm to give you continuous and focused investment advice and/or to make investments on your behalf. As part of our portfolio management services, we will customize an investment portfolio for you according to your risk tolerance and investing objectives. Once we construct an investment portfolio for you, we will monitor your portfolio's performance on an ongoing basis and will rebalance the portfolio as required by changes in market conditions and in your financial circumstances. If you participate in our discretionary portfolio management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm and the appropriate trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account) by providing our firm with your restrictions and guidelines in writing. We also offer non-discretionary portfolio management services. If you enter into non-discretionary arrangements with our firm, we must obtain your approval prior to executing any transactions on behalf of your account. You have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis. Financial Planning and Consulting Services DWM offers financial planning and consulting services which typically involve providing a variety of advisory services to clients regarding the management of their financial resources based upon an analysis of their individual needs. If you retain DWM for financial planning and consulting services, DWM will meet with you to gather information about your financial circumstances, investment goals, objectives, and risk tolerance. This service includes the generation of a comprehensive financial plan, consultations on wealth transfers, estate planning, retirement planning, education funding, and charitable gifting. Upon receipt and analysis of your information, DWM will deliver a written plan to you, designed to help you achieve your stated financial goals and objectives. Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to DWM. You must promptly notify DWM if your financial situation, goals, objectives, or needs change. Form ADV Part 2A/B Diastole Wealth Management, Inc. Page 6 of 33 ver. 1-08062025  You are under no obligation to act on our financial planning recommendations. Should you choose to act on any of our recommendations, you are not obligated to implement the financial plan through any of our other investment advisory services. Moreover, you may act on our recommendations by placing securities transactions with any brokerage firm. Private Investment Funds DWM serves as the Adviser and Eden Investment Partners, LLC (an affiliate of DWM which is owned and controlled by Elizabeth Eden, Elizabeth Cook, and Ethan Eden) which serves as the General Partner to a private investment fund, Eden Partners Absolute Growth Fund, LP (“EPAG”), and is responsible for the formulation and implementation of EPAG’s investment strategies, evaluating and monitoring EPAG’s investments and making all investment decisions for EPAG (as of January 1, 2025, the only other fund, Steamboat Fund, LP merged into Eden Partners Absolute Growth Fund, LP. As such, Steamboat Fund, LP is no longer being offered to prospective investors). Specifically, DWM will manage the assets of EPAG on a discretionary basis in accordance with EPAG’s overall investment objectives. DWM bases its advice on the investment objectives set forth in EPAG’s private placement memorandum, organizational documents, investment management agreement, and/or subscription agreements, as the case may be (each and collectively, the "Governing Documents"). EPAG is available for investment only by institutional investors and other sophisticated, high-net worth investors, who meet the eligibility requirements set forth in their Governing Documents. Interests in EPAG as a pooled investment vehicle is not registered under the Securities Act of 1933, as amended (the “Securities Act”), and such private funds are not registered under the Investment Company Act of 1940, as amended (the “Investment Company Act”). Accordingly, interests in this private fund is offered and sold exclusively to investors satisfying the applicable eligibility and suitability requirements, such as accredited high net worth investors, institutions, and other entities, and is only offered after delivery of a private placement memorandum and execution of the subscription agreement and other offering documents. Investors and prospective investors should refer to EPAG’s offering documents for a complete description of the risks, investment objectives and strategies, fees, the minimum initial capital contribution, or commitment required, and other relevant information pertaining to investments. Selection of Other Advisers DWM may recommend that you use the services of a third-party money manager ("TPMM") to manage all, or a portion of, your investment portfolio. After gathering information about your financial situation and objectives, we may recommend that you engage a specific TPMM or investment program. Factors that we take into consideration when making recommendation(s) include, but are not limited to, the following: the TPMM's performance, methods of analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. DWM will monitor the TPMM(s)' performance to ensure its management and investment style remain aligned with your investment goals and objectives. Types of Investments DWM primarily offers advice on exchange traded funds ("ETFs"), mutual funds, stocks, bonds, option contracts, certificates of deposit, US government securities, pooled investment vehicles, real estate limited partnerships, money market funds, real estate, and real estate investment trusts ("REITs"). Refer to the Methods of Analysis, Investment Strategies and Risk of Loss below for additional disclosures on this topic. Additionally, DWM may advise you on various types of investments based on your stated goals and objectives. DWM may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship. Since DWM’s investment strategies and advice are based on each client's specific financial situation, the investment advice DWM provides to you may be different or conflicting with the advice DWM gives to other clients regarding the same security or investment. Form ADV Part 2A/B Diastole Wealth Management, Inc. Page 7 of 33 ver. 1-08062025  Termination of Account Clients who wish to terminate their account must notify DWM verbally within five (5) business days of its execution with written notice to follow within the next twenty-four (24) hours. If services are terminated within (5) business days of executing the client agreement, services will be terminated without penalty. After the initial five (5) business days, the client may be responsible for payment of fees for the number of days services are provided by DWM prior to receipt of the notice of termination. DWM shall refund any/all pre-paid unearned fees on a pro-rata basis. DWM may tailor its advisory services to the specific needs and objectives of each advisory client. Clients may also impose restrictions on investing in certain securities or types of securities. Most of which is generally covered in the client’s investment advisory agreement or financial planning agreement. Wrap Fee Program DWM does not participate in any wrap fee program. IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, DWM is providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, DWM and its advisory representative are 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. The way DWM makes money creates some conflicts with your interests, so DWM operates under a special rule that requires it to act in your best interest and not put its interests ahead of yours. Under this special rule's provisions, DWM must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. DWM benefits financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest. Assets under Management As of December 31, 2024, DWM provided continuous management services for $268,205,168 in client assets on a discretionary basis, and $109,819,166 in client assets on a non-discretionary basis. DWM’s method for computing the amount of “client assets you manage” is the same method for computing “assets under management.” The amount as disclosed above is rounded to the nearest $100,000. The date of the calculation above is not more than ninety (90) days before the date DWM last updated its brochure. Form ADV Part 2A/B Diastole Wealth Management, Inc. Page 8 of 33 ver. 1-08062025  Item 5. Fees and Compensation Investment Advisory Fees Initial fees are due on the date Client enters into an agreement with the Firm. This fee is based on the beginning absolute value of the account(s) being managed on the inception date of the agreement, pro- rated from the inception date to the end of the next full billing period. On-going fees will be debited directly from Client accounts in advance and calculated quarterly based upon the market value of the account as of the last business day of the previous calendar quarter. Clients may terminate their relationship with DWM without penalty at any time upon written notice and they will receive a pro rata refund of any fees paid in advance. Fees will be billed in accordance with the following fee schedule: Fee Schedule Assets in Account First $1,000,000 Next $1,000,000 Next $1,000,000 Next $1,000,000 Remainder Consulting Fee Standard Program Fee 1.00 % .40 % .80 % .30 % .60 % .25 % .40 % .25% .20 % .25% The Consultant Fee is charged for investment advisory services provided by DWM. The Standard Program Fee is charged for administrative services of DWM to service the Client Accounts. All Clients whose assets are managed in SMA's are charged both the Consultant Fee and the Standard Program Fee. Affiliated Fund assets managed by DWM will also be included in a Client's total assets under management and will be charged a Consultant Fee, however, such affiliated Fund assets will not be charged a Standard Program Fee. Unless instructed to the contrary, DWM will directly debit each Client's account for the Consultant and Standard Program Fees payable to DWM. DWM will deduct its fee directly from your account through the qualified custodian holding your funds and securities and only when you have given DWM written authorization permitting the fees to be paid directly from your account. Further, the qualified custodian will deliver an account statement to you at least quarterly. These account statements will show all disbursements from your account. You should review all statements for accuracy. Fees and minimum account sizes may be negotiable in certain circumstances as occasion may warrant in the judgment of DWM. Certain Clients may pay more or less than others depending upon the amount of assets, the type of account, the anticipated trading activity and the amount for special services required to service the account. Client accounts aggregated for reporting purposes (“house-holded”) may be also aggregated for purposes of DWM’s fee calculations. Furthermore, DWM may also have Clients with older fee arrangements which have been grandfathered. Mutual funds will charge their own investment management fees and will incur their own transaction costs which are in addition to any fees charged by DWM. Detailed information on these costs can be found in the mutual funds’ prospectuses which will be provided to Clients prior to or at the time of investment. DWM is not compensated by any of the mutual fund companies recommended for Client investment. Clients could avoid DWM investment consulting and administrative fees by purchasing funds directly from the mutual fund companies. Although Clients cannot avoid fees by investing directly with mutual funds, DWM often advises financial planning clients to invest directly with mutual funds to avoid additional advisory fees charged by DWM. Financial Planning and Consulting Fees Although DWM offers financial planning/consulting services, it does not charge fees for stand-alone financial planning/consulting services. All terms of our engagement will be evidenced in the agreement Form ADV Part 2A/B Diastole Wealth Management, Inc. Page 9 of 33 ver. 1-08062025  that you sign with DWM. Under no circumstances will DWM require prepayment of a fee in excess of $1,200 for services not performed within six months of the advanced payment. You may terminate the agreement(s) upon written notice to DWM. Private Fund Fees All fees paid to DWM for portfolio management services and affiliated entities are separate and distinct from EPAG’s fees and expenses charged to its investors as members or partners of the private pooled investment vehicle. These fees and expenses are described in EPAG's offering documents. Such fees will generally include a management fee and other fund expenses. A client could possibly invest in EPAG directly, without our services. In that case, the client would not receive the services provided by DWM which are designed, among other things, to assist the client in determining if EPAG is appropriate to the client's financial condition and objectives. Accordingly, the client should review both the fees charged by EPAG and DWM to fully understand the total amount of fees to be paid by the client and thereby evaluate the advisory services being provided. Fees for Selection of Other Advisers DWM’s recommendations to use third party money managers ("TPMM") are included in its portfolio management fee. DWM does not charge a separate fee for the selection of other advisers, nor will we share in the advisory fee you pay directly to the TPMM. Advisory fees that you pay to the TPMM are established and payable in accordance with the Form ADV Part 2 or other equivalent disclosure document provided by each TPMM to whom you are referred. These fees may or may not be negotiable. You should review the recommended TPMM\'s brochure for information on its fees and services. You may be required to sign an agreement directly with the recommended TPMM(s). You may terminate your advisory relationship with the TPMM according to the terms of your agreement with the TPMM. You should review each TPMM's brochure for specific information on how you may terminate your advisory relationship with the TPMM and how you may receive a refund, if applicable. You should contact the TPMM directly for questions regarding your advisory agreement with the TPMM. Insurance Producer Fees Persons providing investment advice on behalf of our firm are also licensed as independent insurance agents. These persons will earn commission-based compensation for selling insurance products, including insurance products they sell to you. Insurance commissions earned by these persons are separate and in addition to our advisory fees. This practice presents a conflict of interest because persons providing investment advice on behalf of our firm who are insurance agents have an incentive to recommend insurance products based on the compensation they receive. You are under no obligation, contractually or otherwise, to purchase insurance products through any person affiliated with DWM. Additional Fees and Expenses As part of our investment advisory services to you, DWM may invest, or recommend that you invest, in mutual funds and exchange traded funds. The fees that you pay to DWM for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds or exchange traded funds (described in each fund's prospectus) to their shareholders. These fees will generally include a management fee and other fund expenses. You will also incur transaction charges and/or brokerage fees when purchasing or selling securities. These charges and fees are typically imposed by the broker-dealer or custodian through whom your account transactions are executed. DWM does not share in any portion of the brokerage fees/transaction charges imposed by the broker-dealer or custodian. To fully understand the total cost you will incur, you should review all the fees charged by mutual funds, exchange traded funds, our firm, and others. For information on our brokerage practices, refer to the Brokerage Practices section of this brochure. Form ADV Part 2A/B Diastole Wealth Management, Inc. Page 10 of 33 ver. 1-08062025  Item 6. Performance-Based Fees and Side-By-Side Management DWM serves as the Adviser, and affiliate, Eden Investment Partners, LLLC, serves as General Partner, to EPAG in which clients may be solicited to invest. DWM, certain members of its management, and other knowledgeable employees may acquire, directly or indirectly, investment interests in EPAG or have other financial interests in EPAG. This presents a conflict of interest because DWM has investments in, and is compensated by, EPAG. Performance-based fees are fees which are based on the share of capital gain or capital appreciation of a client's account. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged a performance- based fee. As such, DWM does currently not charge performance-based fees, nor does DWM provide or participate in side-by-side management. Item 7. Types of Clients DWM primarily provides discretionary and/or non-discretionary investment management services to high- net-worth individuals, individuals other than high net worth individuals, charitable organizations and pooled investment vehicles or private funds which are related private partnerships. In general, DWM does not require a minimum dollar amount to open and maintain an advisory account. The minimum initial investment to invest in EPAG is $250,000. DWM can accept lesser amounts in its sole discretion. Item 8. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis DWM will use one or more of the following methods of analyses or investment strategies when providing investment advice to clients, subject to the clients' investment objectives, risk tolerance, time horizons and stated guidelines: Charting Analysis: involves the gathering and processing of price and volume pattern information for a particular security, sector, broad index, or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data is used to detect departures from expected performance and diversification and predict future price movements and trends. The risk of charting analysis is that our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security and day-to- day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Technical Analysis: involves studying past price patterns, trends, and interrelationships in the financial markets to assess risk-adjusted performance and predict the direction of both the overall market and specific securities. The risk of market timing based on technical analysis is that our analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Fundamental Analysis: involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the true value of the company's stock compared to the current market value. The risk of fundamental analysis is that information obtained may be incorrect and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Form ADV Part 2A/B Diastole Wealth Management, Inc. Page 11 of 33 ver. 1-08062025  Cyclical Analysis: a type of technical analysis that involves evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and may have many fluctuations between long term expansions and contractions. The lengths of economic cycles may be difficult to predict with accuracy and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and consequently the changing value of securities that would be affected by these changing trends. Modern Portfolio Theory: a theory of investment which attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return, by carefully diversifying the proportions of various assets. The market risk is that part of a security's risk that is common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Investment Strategies DWM will use the following strategies in managing client accounts. Investment strategies and advice may vary depending upon each client's specific financial situation. As such, we determine investments and allocations based upon the client's predefined objectives, risk tolerance, time horizon, financial horizon, financial information, liquidity needs, and other various suitability factors. The client's restrictions and guidelines may affect the composition of the client's portfolio. Long-Term Purchases: securities purchased with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. The risks of using a long- term purchase strategy generally assumes the financial markets will go up in the long-term which may not be the case. There is also the risk that the segment of the market that you are invested in or perhaps just your particular investment will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short-term in other investments. Short-Term Purchases: securities 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. The risks of using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short-term which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. There are many factors that can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a smaller impact over longer periods of times. Margin Transactions: a securities transaction in which an investor borrows money to purchase a security, in which case the security serves as collateral on the loan. The risks of margin transaction is that if the value of the shares drops sufficiently, the investor will be required to either deposit more cash into the account or sell a portion of the stock in order to maintain the margin requirements of the account. This is known as a "margin call." An investor's overall risk includes the amount of money invested plus the amount that was loaned to them. Option Writing: a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the expiration date of the option. When an investor sells a call option, he or she must deliver to the buyer a specified number of shares if the buyer exercises the option. When an investor sells a put option, he or she must pay the strike price per share if the buyer exercises the option, and will receive the specified number of shares. The option writer/seller receives a premium (the market price of the option at a particular time) in exchange for writing the option. The risks are that options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Cash Management DWM manages cash balances in your account based on the yield, and the financial soundness of the money markets and other short-term instruments. Form ADV Part 2A/B Diastole Wealth Management, Inc. Page 12 of 33 ver. 1-08062025  Tax Considerations DWM’s strategies and investments may have unique and significant tax implications. However, unless DWM specifically agrees otherwise, and in writing, tax efficiency is not our primary consideration in the management of your assets. Regardless of your account size or any other factors, DWM strongly recommends that you consult with a tax professional regarding the investing of your assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. You are responsible for contacting your tax advisor to determine if this accounting method is the right choice for you. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately and DWM will alert your account custodian of your individually selected accounting method. Decisions about cost basis accounting methods will need to be made before trades settle, as the cost basis method cannot be changed after settlement. Risk of Loss As with most investment products, because investment portfolios include securities, investing in securities involves risk of loss that you as our client should be prepared to bear. DWM does not represent or guarantee that its 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. DWM cannot offer any guarantees or promises that your financial goals and objectives will be met. Past performance is in no way an indication of future performance. Economic Conditions Changes in economic conditions, including, for example, interest rates, inflation rates, currency and exchange rates, industry conditions, competition, technological developments, trade relationships, supply- chain disruptions, economic sanctions, political and diplomatic events, economic sanctions, tax laws and innumerable other factors, can affect substantially and adversely the investment performance of Clients. Economic, political, and financial conditions, or industry or economic trends and developments, may, from time to time, and for varying periods of time, cause volatility, illiquidity, or other potentially adverse effects in the financial markets. Economic or political turmoil, a deterioration of diplomatic relations or a natural or man-made disaster in a region or country where DWM's Client assets are invested may result in adverse consequences to such Clients. None of these conditions are or will be within the control of DWM, and no assurances can be given that DWM will anticipate these developments. Equity Risks The material risks associated with these strategies are: Equity Market Risk: Overall stock market risks may affect the value of the investments in equity strategies. Factors such as U.S. economic growth and market conditions, interest rates, and political events affect the equity markets. Management Risk: Our judgments about the attractiveness, value and potential appreciation of a particular asset class or individual security may be incorrect and there is no guarantee that individual securities will perform as anticipated. The value of an individual security can be more volatile than the market as a whole or our intrinsic value approach may fail to produce the intended results. Our estimate of intrinsic value may be wrong or even if our estimate of intrinsic value is correct, it may take a long period of time before the price and intrinsic value converge. Small and Mid-Cap Company Risk: Investments in small and mid-cap companies may be riskier than investments in larger, more established companies. The securities of these companies may trade less frequently and in smaller volumes than securities of larger companies. In addition, small and mid-cap companies may be more vulnerable to economic, market and industry changes. Because smaller companies may have limited product lines, markets, or financial resources, or may depend on a few key employees, they may be more susceptible to particular economic events or competitive factors than larger capitalization companies. Short Sale Risk: Short sales are speculative transactions and involve special risks. In order to initiate a short position, a security must be borrowed. Strategies that execute short sales may incur a loss if the Form ADV Part 2A/B Diastole Wealth Management, Inc. Page 13 of 33 ver. 1-08062025  price of the security sold short increases in value between the date of the short sale and the date when we purchase the security to replace the borrowed security. Losses are potentially unlimited in a short sale transaction. Fixed Income Risks The material risks associated with this strategy are: Fixed Income Market Risk: Fixed income securities increase or decrease in value based on changes in interest rates. If rates increase, the value of fixed income securities generally declines. On the other hand, if rates fall, the value of the fixed income securities generally increases. Management Risk: Our judgments about the attractiveness, value, and potential appreciation of a particular asset class or individual security may be incorrect and there is no guarantee that individual securities will perform as anticipated. The value of an individual security can be more volatile than the market as a whole, and our intrinsic value approach may fail to produce the intended results. Credit Risk: There is a risk that issuers and counterparties will not make payments on the securities they issue. In addition, the credit quality of securities may be lowered if an issuer’s financial condition changes. Lower credit quality may lead to greater volatility in the price of a security which may affect liquidity and our ability to sell the security. Real Estate Risk: Real Estate Investment Trusts (REITS), although not a direct investment in real estate, are subject to the risks associated with investing in real estate. The value of these securities will rise and fall in response to many factors including economic conditions, the demand for rental property and changes in interest rates. Structured Instrument Risk: Structured instruments may be less liquid than other debt securities, and the price of structured instruments may be more volatile. Although structured instruments may be sold in the form of a corporate debt obligation, they may not have some of the protection against counterparty default that may be available with publicly traded debt securities. ETF Risks The material risks associated with this strategy are: International Limitations: While the U.S. has a plethora of ETF products, some countries only have a few exchange traded funds in which to invest. And those regions that do offer market ETFs, usually only include large-cap products leaving a lack of mid and small-sized funds. Low Trading Volumes: When ETFs have low trading volumes, the advantage of purchasing and ETF over and index or equity diminishes. The bid-ask spread can be too wide to be cost-effective. Market Makers tend to be tighter on securities that are more liquid (barring any unforeseen news or circumstances). Long Investment Horizon: The intraday trading opportunities created by ETFs may not fit into a long-term investor’s strategy. This is more of an advantage for short-term ETF traders. So, as an investor, it will be important to layout your investing goals before you decide how to include ETFs in your portfolio. Inactivity: Some ETFs are not as actively traded as others. It can be a sector-related issue or even a regional issue. When this situation occurs, it may be more effective to invest in managed fund where activity is higher. Tax Implications: In the case of foreign ETFs, sometimes there may be a tax advantage by opting to invest in an international portfolio. Tax laws vary from country to country, so it may be beneficial for your tax return to find other foreign investments. There are many benefits to including ETFs in your portfolio, however it is important to understand that they are not the ideal investment for every situation. ETFs should be evaluated on a case-by-case basis for every investing strategy. Commercial Paper: Commercial Paper (CP) is, in most cases, an unsecured promissory note that is issued with a maturity of 270 days or less. Being unsecured the risk to the investor is that the issuer may default. There is less risk in asset based commercial paper (ABCP). The difference between ABCP and Form ADV Part 2A/B Diastole Wealth Management, Inc. Page 14 of 33 ver. 1-08062025  CP is that instead of being an unsecured promissory note representing an obligation of the issuing company, ABCP is backed by securities. Therefore, the perceived quality of the ABCP depends on the underlying securities. Limited Partnerships: A limited partnership is a financial affiliation that includes at least one general partner and a number of limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner does not usually invest any capital but has management authority and unlimited liability. That is, the general partner runs the business and, in the event of bankruptcy, is responsible for all debts not paid or discharged. The limited partners have no management authority and confine their participation to their capital investment. That is, limited partners invest a certain amount of money and have nothing else to do with the business. However, their liability is limited to the amount of the investment. In the worst-case scenario for a limited partner, he/she loses what he/she invested. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. Other Risk Considerations When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of any potential losses. The following risks may not be all-inclusive but should be considered carefully by a prospective client before retaining our services. Liquidity Risk: The risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or it may not be possible to sell the investment at all. Inflation and Interest Rate Risk: 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 a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many types of fixed income investments to decline. Horizon and Longevity Risk: The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments that you were expecting to hold for the long term. If you must sell at a time that the markets are down, you may lose money. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for people who are retired or are nearing retirement. Sector risks: Investing in a particular sector is subject to cyclical market conditions and charges. Foreign investments risk: Non-U.S. investments, currency and commodity investments may contain additional risks associated with government, economic, political or currency volatility. Emerging markets risk: Emerging markets can experience high volatility and risk in the short term. Cybersecurity Risk: The computer systems, networks and devices used by us and our service providers employ a variety of protections designed to prevent damage or interruption from computer viruses, network and computer failures and cyberattacks. Despite such protections, systems, networks, and devices potentially can be breached. Cyberattacks include, but are not limited to, gaining unauthorized access to digital systems for purposes of corrupting data, or causing operational disruption, as well as denial-of- service attacks on websites. Cyber incidents may cause disruptions and impact business operations, potentially resulting in financial losses, the inability of us or our service providers to trade, violations of privacy and other laws, regulatory fines, reputational damage, reimbursement costs and additional compliance costs, as well as the inadvertent release of confidential information. Item 9. Disciplinary Information Disclosure Events There are no disclosure events involving a criminal or civil action in a domestic, foreign, or military court of competent jurisdiction in which DWM or its management personnel are involved. Form ADV Part 2A/B Diastole Wealth Management, Inc. Page 15 of 33 ver. 1-08062025  Regarding disclosure events involving an administrative proceeding before the SEC, on September 10, 2021, the Securities Exchange Commission ("SEC") issued a Settled Order ("Order") to which Diastole Wealth Management, Inc. ("DWM") and Elizabeth Eden, Co-Founder and Chief Compliance Officer ("Respondents"), consented without admitting or denying the findings of the Order to settle Case Number: 3-20534. The Order finds that the Respondents violated certain provisions of the Investment Advisers Act of 1940 and orders that: Respondents are censured, Respondents ordered to cease and desist from committing or causing any violations and any future violations of the Investment Advisers Act of 1940, DWM pay a civil penalty of $100,000 and Ms. Eden pay a civil penalty of $60,000, and Ms. Eden is limited in her activities from serving as a chief compliance officer. DWM agreed to engage an independent compliance consultant to review certain aspects of DWM's compliance program and make recommendations. On May 1, 2019, the SEC found that the Respondents did not adequately disclose certain conflicts of interest relating to the investments made by a private fund they advised, Eden Partners Absolute Growth Fund ("EPAG"), in notes issued by Market 76, Inc ("M76"), an affiliated company owned by Ms. Eden's son. According to the Order, a portion of the proceeds from the EPAG investment in M76 were transferred to DWM as repayment of loans that DWM previously had made to M76. EPAG has been reimbursed for that portion of EPAG's investment in M76 that was transferred to DWM. The Order also found that DWM did not timely deliver audited financial statements for EPAG to the Fund's investors. Further details on these matters related to DWM's disciplinary history can be found on the IAPD. The IAPD link is www.adviserinfo.sec.gov. There are no other disclosure events involving an administrative proceeding before any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority in which DWM or its management personnel are involved. There are no disclosure events involving a self-regulatory organization (SRO) proceeding in which DWM or its management personnel are involved. Item 10. Other Financial Industry Activities and Affiliations Neither DWM nor any of its management persons are registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. Neither DWM nor any of its management persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. DWM also provides comprehensive financial planning services, which may involve areas or activities other than giving investment advice, such as insurance planning, retirement planning, estate planning, and business planning. Arrangements with Affiliated Entities Affiliated Private Funds DWM serves as the Adviser and its affiliated entity, Eden Investment Partners, LLC, is the General Partner to Eden Partners Absolute Growth Fund, LP (“EPAG”) and Steamboat Fund, LP, (“Steamboat”) private pooled investment vehicles in which DWM’s clients are solicited to invest. As disclosed in Item 4 above, as of January 1, 2025, Steamboat merged into EPAG. As such, Steamboat is no longer being offered to prospective investors. EPAG is offered to certain sophisticated investors, who meet certain requirements under applicable state and/or federal securities laws. Investors to whom EPAG is offered will receive a private placement memorandum and other offering documents. The terms and conditions for participation in EPAG, including management and/or performance-based fees, conflicts of interest, risk factors, and liquidity constraints, are set forth in EPAG's offering document. The fees charged by EPAG are separate and apart from DWM's advisory fees. Clients should refer to the offering documents for a complete description of the fees, investment objectives, risks and other relevant information associated Form ADV Part 2A/B Diastole Wealth Management, Inc. Page 16 of 33 ver. 1-08062025  with investing in EPAG. Persons affiliated with DWM have made an investment in EPAG and may have an incentive to recommend EPAG over other investments. EPAG holds bonds in an affiliated entity, Market 76, which is owned and operated by Elizabeth Eden's son. This presents a conflict of interest because DWM owns and has investments in and is compensated by, EPAG. Therefore, DWM has a financial incentive to recommend EPAG to its clients. These conflicts are mitigated by DWM's fiduciary obligation to act in the best interest of clients, contractual limitations that govern DWM's activities as adviser or general partner, as applicable, and the requirement that DWM not to place its interests before clients' interests when managing EPAG. Clients who are investors in EPAG should refer to EPAG's offering documents for detailed disclosures. These bonds are excluded from EPAG’s total assets on which the Limited Partner's management fee is calculated. DWM does not charge fees on the M76 bonds held in EPAG. Northcreek Funds EPAG also has invested in a series of unaffiliated private equity funds, Northcreek Fund II, III, and IV. Additionally, EPAG has also invested in Northcreek Fund I for which Elizabeth Eden serves as one of the general partners and receives compensation in the amount of 30% of the total general partnership interest. Elizabeth Eden has decided not to receive this compensation directly and instead, assigns this compensation to the EPAG for the benefit of its limited partners. This presents a conflict of interest because as noted above DWM owns and has investments in, and is compensated by, EPAG. Therefore, DWM has a financial incentive to recommend EPAG to its clients. These conflicts are mitigated by DWM's fiduciary obligation to act in the best interest of clients, contractual limitations that govern DWM's activities as adviser or general partner, as applicable, and the requirement that DWM not to place its interests before clients' interests when managing EPAG. Clients who are investors in EPAG should refer to EPAG's offering documents for detailed disclosures. Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in EPAG’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may maintain, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund and acknowledges and accepts the various risk factors that are associated with such an investment. DWM and certain members of its management have acquired, directly or indirectly, investment interests in EPAG or have other financial interests (e.g., General Partner) in EPAG. As Investors, they have an incentive to devote more time to EPAG than to Clients or to provide limited investment opportunities to EPAG instead of Clients. Furthermore, they may have an incentive to recommend EPAG rather than recommending other investments. DWM addresses these conflicts by disclosing them in this brochure and in the offering documents of the Fund. While DWM believes these relationships are commonplace in the investment industry and bring added value to Clients, the members of DWM's management and all DWM employees are fiduciaries and are required to act at all times in accordance with DWM's Code of Ethics and to act only in the best interest of their Clients. Insurance Products Persons providing investment advice on behalf of DWM may be licensed as insurance agents. These persons will earn commission-based compensation for selling insurance products, including insurance products they sell to you. Insurance commissions earned by these persons are separate from our advisory fees. See the Fees and Compensation section in this brochure for more information on the compensation received by insurance agents who are affiliated with DWM. Recommendation of Other Advisers DWM may recommend that you use a third-party money manager ("TPMM") based on your needs and suitability. DWM will not receive separate compensation, directly or indirectly, from the TPMM for recommending that you use their services. Moreover, DWM does not have any other business Form ADV Part 2A/B Diastole Wealth Management, Inc. Page 17 of 33 ver. 1-08062025  relationships with the recommended TPMM(s). Refer to the Advisory Business section above for additional disclosures on this topic. Item 11. Code of Ethics, Participation/Interest in Client Transactions and Personal Trading Code of Ethics DWM strives to comply with applicable laws and regulations governing its practices. Therefore, DWM’s Code of Ethics includes guidelines for professional standards of conduct for its associated persons. DWM has implemented a Code of Ethics that defines its fiduciary commitment to each client. The Code of Ethics addresses topics such as employee ethics, insider trading, and conflicts of interest. The Code of Ethics applies to all persons associated with DWM. The Code of Ethics was developed to provide general ethical guidelines and specific instructions regarding our duties to the client. DWM, and all persons associated with DWM, owe a duty of loyalty, fairness, and good faith towards each client. It is the obligation of persons associated with DWM to adhere not only to the specific provisions of the Code of Ethics, but also to the general principles that guide the Code of Ethics. Persons associated with our firm are also required to report any violations of our Code of Ethics. Additionally, DWM maintains and enforces written policies reasonably designed to prevent the misuse or dissemination of material, nonpublic information about you or your account holdings by persons associated with DWM. A complete copy of DWM’s Code of Ethics is available to any client or prospective client upon request. Participation/Interest in Client Transactions DWM serves as the Adviser, and our affiliated entity, Eden Investment Partners, LLC, is the General Partner to EPAG in which clients may be solicited to invest. DWM, certain members of its management, may acquire, directly or indirectly, investment interests in EPAG or have other financial interests (e.g., General Partner) in EPAG. This presents a conflict of interest because DWM has investments and/or is compensated by EPAG. Conflicts that arise are mitigated through DWM's fiduciary obligation to act in the best interest of clients, contractual limitations that govern DWM's activities as adviser or general partner, as applicable, and the requirement of DWM not to place its interests before its clients' interests when managing EPAG. Clients who are investors of EPAG should, refer to EPAG's offering documents for detailed disclosures. Personal Trading Practices DWM, or persons associated with DWM, may buy or sell the same securities that it recommends to you or securities in which you are already invested. Owning the same securities recommended (purchase or sell) to clients presents a conflict of interest that, as fiduciaries, must be disclosed to clients and mitigated through policies and procedures. As noted above, DWM has adopted the Code of Ethics to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities as recommended (purchase or sell) to clients. The fiduciary duty to act in the best interest of its clients can be violated if personal trades are made with more advantageous terms than client trades, or by trading based on material non-public information. This risk is mitigated by DWM requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer ("CCO") or delegate. DWM has also adopted written policies and procedures to detect the misuse of material, non-public information. Aggregated Trading DWM, or persons associated with DWM, may buy or sell securities for you at the same time DWM or its associated persons buy or sell such securities for its or their own account. DWM may also combine its orders to purchase securities with your orders to purchase securities ("aggregated trading"). Refer to the Brokerage Practices section in this brochure for information on our aggregated trading practices. A conflict of interest exists in such cases because DWM has the ability to trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, it is Form ADV Part 2A/B Diastole Wealth Management, Inc. Page 18 of 33 ver. 1-08062025  DWM’s policy that neither the firm nor its associated persons shall have priority over your account in the purchase or sale of securities. Item 12. Brokerage Practices Research and Other Soft Dollar Benefits Soft dollars are revenue programs offered by broker dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. DWM does not participate in soft dollar programs sponsored or offered by any broker- dealer/custodian. However, DWM receives certain economic benefits from the custodian(s). Brokerage for Client Referrals DWM does not receive client referrals from broker-dealers in exchange for cash or other compensation, such as brokerage services or research, nor does DWM compensate non-employee (outside) consultants, individuals, and/or entities for client referrals. Directed Brokerage DWM routinely requires that you direct DWM to execute transactions through the established accounts at the designated custodian(s) listed below. As such, we may be unable to achieve the most favorable execution of your transactions and you may pay higher brokerage commissions than you might otherwise pay through another broker-dealer that offers the same types of services. Not all advisers require their clients to direct brokerage. DWM will generally recommend that clients establish their advisory account[s] at Charles Schwab & Co., Inc. ("Schwab") , a FINRA-registered broker-dealer and member of SIPC. Client assets must be maintained in an account at a "qualified custodian," generally a broker-dealer or bank. Schwab will serve as the "qualified custodian." DWM maintains an institutional relationship with Schwab, whereby we receive economic benefits from Schwab. DWM does not maintain custody of Clients assets that it manages, although DWM may be deemed to have custody of Clients assets if Clients grant authority to withdraw assets from Client accounts (see Item 15—Custody, below. DWM is independently owned and operated and is not affiliated with Schwab. Schwab will hold Client assets in a brokerage account and buy and sell securities when DWM instruct them to. While DWM recommends that Clients use Schwab as custodian/broker, Clients will decide whether to do so and will open the account with Schwab by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below. Clients should consider these conflicts of interest when selecting the custodian, DWM does not open the account for Clients, although it may assist Clients in doing so. Even though Client accounts are maintained at Schwab, and DWM anticipate that most trades will be executed through Schwab, DWM can still use other brokers to execute trades for Client accounts as described below (see "Your brokerage and custody costs"). How We Select Custodians/Brokers When appropriate for certain clients, DWM seeks to recommend Schwab, a custodian/broker that will hold Client assets and execute transactions. When considering whether the terms that Schwab provides are, overall, most advantageous to Clients when compared with other available providers and their services, we take into account a wide range of factors, including: • Capability to execute, clear, and settle trades (buy and sell securities for your account) • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) • Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.) • Availability of investment research and tools that assist us in making investment decisions Form ADV Part 2A/B Diastole Wealth Management, Inc. Page 19 of 33 ver. 1-08062025  • Quality of services • Reputation, financial strength, security, and stability • Prior service to us and our clients • Services delivered or paid for by Schwab Your Brokerage and Custody Costs For the clients' accounts that Schwab maintains, Schwab generally does not charge Clients separately for custody services but is compensated by charging Clients commissions or other fees on trades that it executes or that settle into your Schwab account. Certain trades (for example, many mutual funds and ETFs) may not incur Schwab commissions or transaction fees. Schwab is also compensated by earning interest on the uninvested cash in a Client's account in Schwab's Cash Features Program. Schwab charges Clients a flat dollar amount as a "prime broker" or "trade away" fee for each trade that DWM has executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into a Client's Schwab account. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. Because of this, in order to minimize your trading costs, DWM has Schwab execute most trades for Client accounts. DWM is not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although DWM is not required to execute all trades through Schwab, we have determined that having Schwab execute most trades is consistent with our duty to seek "best execution" of Client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see "How we select brokers/custodians"). By using another broker or dealer Clients may pay lower transaction costs. Products and Services Available to Us From Schwab Schwab Advisor Services™ is Schwab's business serving independent investment advisory firms like DWM. They provide DWM and its Clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to Schwab retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through DWM. Schwab also makes available various support services. Some of those services help DWM manage or administer its Clients' accounts, while others help DWM manage and grow its business. Schwab's support services are generally available on an unsolicited basis (we do not have to request them) and at no charge to DWM. Following is a more detailed description of Schwab's support services: Schwab's institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by DWM's Clients. Schwab's services described in this paragraph generally benefit Clients and Client accounts. Schwab also makes available to DWM other products and services that benefit us but do not directly benefit Clients or Client accounts. These products and services assist us in managing and administering our Clients' accounts and operating our firm. They include investment research, both Schwab's own and that of third parties. DWM uses this research to service all or a substantial number of our Clients' accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • Provide access to Client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts Form ADV Part 2A/B Diastole Wealth Management, Inc. Page 20 of 33 ver. 1-08062025  • Assist with back-office functions, recordkeeping, and client reporting Schwab also offers other services intended to help DWM manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and related compliance needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab also discounts or waives its fees for some of these services or pays all or a part of a third party's fees. If you did not maintain your account with Schwab, the Advisor would be required to pay for these services from our own resources. The availability of these services from Schwab benefits us because DWM does not have to produce or purchase them. DWM does not have to pay for Schwab's services. These services are not contingent upon DWM committing any specific amount of business to Schwab in trading commissions or assets in custody. The fact that DWM receives these benefits from Schwab is an incentive for us to recommend the use of Schwab rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. DWM believes, however, that taken in the aggregate, DWM's recommendation of Schwab as custodian and broker, when appropriate for certain clients, is in the best interests of Clients. DWM's selection is primarily supported by the scope, quality, and price of Schwab's services (see "How we select brokers/custodians") and not Schwab's services that benefit only DWM. EPAG’s Custodian DWM also utilizes UBS Financial Services, Inc ("UBS), a FINRA-registered broker-dealer and member of SIPC. UBS will serve as the "qualified custodian" for EPAG. DWM maintains an institutional relationship with UBS whereby we receive economic benefits from UBS as the custodian for the Fund. DWM is independently owned and operated and is not affiliated with UBS. DWM will have access to EPAG's funds and securities since an affiliated entity, Eden Investment Partners, LLC serves as the General Partner to EPAG, and therefore DWM is deemed to have custody over such funds and securities (see Item 15—Custody, below). DWM believes that UBS provides quality execution services at competitive prices. Price is not the sole factor DWM considers in evaluating best execution. DWM also considers the quality of the brokerage services provided by UBS including the value of the firm's reputation, execution capabilities, commission rates, and responsiveness. In recognition of the value of the services UBS provides, clients may pay higher commissions and/or trading costs than those that may be available elsewhere. Aggregation of Client Orders DWM combines multiple orders for shares of the same securities purchased for discretionary advisory accounts that it manages (this practice is commonly referred to as "aggregated trading"). DWM will then distribute a portion of the shares to participating accounts in a fair and equitable manner. Generally, participating accounts will pay a fixed transaction cost regardless of the number of shares transacted. In certain cases, each participating account pays an average price per share for all transactions and pays a proportionate share of all transaction costs on any given day. In the event an order is only partially filled, the shares will be allocated to participating accounts in a fair and equitable manner, typically in proportion to the size of each client's order. Accounts owned by DWM or its associated persons may participate in aggregated trading with your accounts; however, they will not be given preferential treatment. DWM does not aggregate trades for non-discretionary accounts. Accordingly, non-discretionary accounts may pay different costs than discretionary accounts pay. If you enter into non-discretionary arrangements Form ADV Part 2A/B Diastole Wealth Management, Inc. Page 21 of 33 ver. 1-08062025  with DWM, it may not be able to buy and sell the same quantities of securities for you and you may pay higher commissions, fees, and/or transaction costs than clients who enter into discretionary arrangements with our firm. Mutual Fund Share Classes Mutual funds are sold with different share classes, which carry different cost structures. Each available share class is described in the mutual fund's prospectus. When DWM purchases, or recommends the purchase of, mutual funds for a client, DWM selects the share class that is deemed to be in the client's best interest, taking into consideration the availability of advisory, institutional or retirement plan share classes, initial and ongoing share class costs, transaction costs (if any), tax implications, cost basis and other factors. DWM also reviews the mutual funds held in accounts that come under our management to determine whether a more beneficial share class is available, considering cost, tax implications, and the impact of contingent or deferred sales charges. Item 13. Review of Accounts Portfolio Management Reviews Each of DWM's investment advisor representatives will review and monitor their respective clients' accounts on a monthly basis and will conduct account reviews at least annually, to ensure the advisory services provided to you are consistent with your investment needs and objectives. Additional reviews may be conducted based on various circumstances, including, but not limited to: contributions and withdrawals; year-end tax planning; market moving events; security specific events, and/or, changes in your risk/return objectives. You will receive trade confirmations and monthly or quarterly statements from your account custodian(s). DWM will provide you with additional or regular written reports in conjunction with account reviews. Reports DWM provides to you will contain relevant account and/or market-related information such as an inventory of account holdings and account performance, etc. You will receive trade confirmations and monthly or quarterly statements from your account custodian(s). Financial Plan Reviews Each of DWM's investment advisor representatives will review and monitor their respective clients' financial plans as needed. These reviews are provided as part of the portfolio management contracted services. DWM does not assess additional fees for financial plan reviews. Generally, DWM will contact you periodically to determine whether any updates may be needed based on changes in your circumstances. Changed circumstances may include, but are not limited to marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss and/or disability, among others. We recommend meeting with you at least annually to review and update your plan if needed. Additional reviews will be conducted upon your request. Written updates to the financial plan may be provided in conjunction with the review. If you implement financial planning advice, you will receive trade confirmations and monthly or quarterly statements from relevant custodians. Private Fund Reviews Each of the Private Funds are reviewed at least on a monthly basis. Limited partners will receive quarterly performance information based on the valuation reports received monthly from each Fund's administrator. Item 14. Client Referrals and Other Compensation Receipt of Economic Benefit (non-client) Charles Schwab & Co., Inc - Institutional DWM receives an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab. We benefit from the products and services provided because the cost of these services would otherwise be borne directly by us, and this creates a conflict. You should consider these Form ADV Part 2A/B Diastole Wealth Management, Inc. Page 22 of 33 ver. 1-08062025  conflicts of interest when selecting a custodian. These products and services, how they benefit us, and the related conflicts of interest are described above (see Item 12—Brokerage Practices). As disclosed under the Fees and Compensation section in this brochure, persons providing investment advice on behalf of our firm are licensed insurance agents. For information on the conflicts of interest this presents, and how we address these conflicts, refer to the Fees and Compensation section. Direct/Indirect Compensation for Client Referrals DWM does not receive any compensation from any third-party in connection with providing investment advice to you nor does DWM compensate any individual or firm for client referrals. Refer to the Brokerage Practices section above for disclosures on research and other benefits we may receive resulting from our relationship with your account custodian. Item 15. Custody Debit Fees All clients must place their assets with a "qualified custodian." Clients are required to engage the custodian to retain their funds and securities and direct DWM to utilize that custodian for the client's security transactions. Under securities regulations, we are deemed to have custody of your assets if, for example, you authorize us to instruct Schwab to deduct our advisory fees directly from your account or if you grant us authority to move your money to another person's account. Schwab maintains actual custody of your assets. Clients should review statements provided by the custodian at least quarterly and compare them to any reports provided by DWM to ensure accuracy, as the custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. Private Funds As previously disclosed in Item 4 above, DWM serves as the Adviser, and our affiliated entity, Eden Investment Partners, LLC, is the General Partner to EPAG, a private pooled investment vehicle in which our clients are solicited to invest. Under this structure, DWM will have access to EPAG's funds and securities since an affiliated entity, Eden Investment Partners, LLC serves as the General Partner to EPAG, and therefore DWM is deemed to have custody over such funds and securities. DWM is required by applicable regulations to provide each investor in EPAG with audited annual financial statements. If you are an investor in EPAG and have questions regarding the financial statements or if you did not receive a copy, contact us directly at (203) 458-5220. Wire Transfer and/or Standing Letter of Authorization DWM and its associated person may effect wire transfers from client accounts to one or more third parties designated, in writing, by the client without obtaining written client consent for each separate, individual transaction as long as the client has provided us with written authorization to do so. Such written authorization is known as a Standing Letter of Authorization. An adviser with authority to conduct such third-party wire transfers has access to the client's assets and therefore has custody of the client's assets in any related accounts. However, DWM does not have to obtain a surprise annual audit, as DWM otherwise would be required to by reason of having custody, as long as DWM meets the following criteria: 1. You provide a written, signed instruction to the qualified custodian that includes the third party's name and address or account number at a custodian; 2. You authorize DWM in writing to direct transfers to the third party either on a specified schedule or from time to time; 3. Your qualified custodian verifies your authorization (e.g., signature review) and provides a transfer of funds notice to you promptly after each transfer; 4. You can terminate or change the instruction; 5. DWM has no authority or ability to designate or change the identity of the third party, Form ADV Part 2A/B Diastole Wealth Management, Inc. Page 23 of 33 ver. 1-08062025  the address, or any other information about the third party; 6. DWM maintains records showing that the third party is not a related party to us nor located at the same address as us; and 7. Your qualified custodian sends you, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction The qualified custodian of each client account sends or makes available, at least on a quarterly basis, account statements directly to each client. DWM urges clients to carefully review these account statements from their qualified custodians compare to any reports provided by DWM to ensure accuracy, as the custodian does not perform this review. Item 16. Investment Discretion Before DWM can buy or sell securities on your behalf, you must first sign our discretionary management agreement and the appropriate trading authorization forms. You may grant DWM discretion over the selection and amount of securities to be purchased or sold for your account(s) without obtaining your consent or approval prior to each transaction. You may specify investment objectives, guidelines, and/or impose certain conditions or investment parameters for your account(s). For example, you may specify that the investment in any particular stock or industry should not exceed specified percentages of the value of the portfolio and/or restrictions or prohibitions of transactions in the securities of a specific industry or security. Refer to the Advisory Business section in this brochure for more information on our discretionary management services. If you enter into non-discretionary arrangements with DWM, DWM will obtain your approval prior to the execution of any transactions for your account(s). You have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis. DWM, or an affiliate, provides investment advisory services to EPAG on a discretionary basis and therefore has the authority to determine the underlying funds and/or securities to be bought or sold, the amount of securities to be bought or sold, the broker-dealers to be used and any fees to be paid by the Funds. Item 17. Voting Client Securities DWM will not vote proxies on behalf of your advisory accounts. At your request, DWM may offer you advice regarding corporate actions and the exercise of your proxy voting rights. If you own shares of applicable securities, you are responsible for exercising your right to vote as a shareholder. In most cases, you will receive proxy materials directly from the account custodian. However, in the event DWM were to receive any written or electronic proxy materials, DWM would forward them directly to you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, DWM would forward any electronic solicitations to vote proxies. Item 18. Financial Information Pre-Payment of Fees DWM does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. Material Impact of Discretionary Authority DWM may exercise discretionary authority over certain client funds or securities. However, DWM does not anticipate any financial condition that may be reasonably likely to impair its ability to meet contractual commitments to clients at this time. Custody Disclosure Please see Custody section above for further details. Form ADV Part 2A/B Diastole Wealth Management, Inc. Page 24 of 33 ver. 1-08062025  Bankruptcy Disclosure DWM has not been the subject of a bankruptcy petition at any time during the past ten years. Payable Notes DWM is owned by Elizabeth Cook, Elizabeth Eden and her son, Ethan Eden who also worked at DWM, and Ethan's wife Meredith P. Eden, who is COO/CCO of DWM. Ethan left DWM and formed software companies ("Companies") to make tools to help small investment advisers. In 2017, DWM periodically made loans to the Companies that Eden's son principally owned and operated and any portion of the EPAG’s investment in the Companies could be used to repay loans DWM had made to the Companies. Between May 2017 and July 2017, DWM and Eden caused EPAG to purchase convertible notes totaling $446,000 from the Companies. These investments were evidenced by six separate notes payable from the Companies to EPAG or EPAG's general partner, Eden Investment Partners, LLC. The notes all had two-year terms. EPAG's limited partners were all also individual advisory clients. Several of DWM's client invested in the software companies. This creates a material conflict of interest due to the family relationship between Eden and her son, several of DWM's clients invested in the software companies, EPAG invested in Eden's son's companies, and the Companies owed periodic debts to DWM as the investment amounts could and would be used to pay off loans DWM. DWM addresses these conflicts by disclosing them in this brochure and in the offering documents and providing the "Disclosure and Conflicts of Interest Waiver" to certain DWM individual clients and EPAG Fund investors. All of the EPAG Fund's investors, or limited partners, are individual clients of DWM, and therefore DWM and Eden owe a fiduciary duty to both EPAG and its limited partners. The members of DWM's management and all DWM employees are fiduciaries and are required to act at all times in accordance with DWMs Code of Ethics and to act only in the best interest of clients. Additional Information Trade Errors In the event a trading error occurs in your account, DWM’s policy is to restore your account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Class Action Lawsuits DWM does not determine if securities held by you are the subject of a class action lawsuit or whether you are eligible to participate in class action settlements or litigation nor does DWM initiate or participate in litigation to recover damages on your behalf for injuries as a result of actions, misconduct, or negligence by issuers of securities held by you. Privacy Policy Notice Your privacy is important to us. Your personal information is kept secure. Under federal and state law, you have a right to know what information is being collected about you and how that information will be used. DWM collects nonpublic personal information about you from the following sources: • • • Information DWM receives from you on applications or other forms. Information about your transactions with DWM; and Information that you specifically have had your other professional advisors forward to DWM. DWM does not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted or required by law, or as directed by you: • • Under law, the information DWM collects is provided to companies that perform support services on our behalf as necessary to effect, administer, or process a transaction, or for maintaining and servicing your account; As directed by you, DWM will be working with your other professional advisors and DWM will provide information in our possession that is reasonably requested by the other advisors. Form ADV Part 2A/B Diastole Wealth Management, Inc. Page 25 of 33 ver. 1-08062025  DWM does not give or sell information about you or your accounts to any other company, individual or group. DWM restricts access to nonpublic personal information about you to those employees who need to know that information to provide services to you. DWM maintains physical, administrative, and technical procedural safeguards to protect your nonpublic personal information. You do not need to call or do anything as a result of this notice. It is meant to inform you of how DWM safeguards your nonpublic personal information. IRA Rollover Considerations As part of our investment advisory services to you, DWM may recommend that you withdraw the assets from your employer's retirement plan and roll the assets over to an individual retirement account ("IRA") that we will manage on your behalf. If you elect to roll the assets to an IRA that is subject to DWM’s management, you will be charged an asset-based fee as set forth in the agreement you executed with DWM. This practice presents a conflict of interest because persons providing investment advice on our behalf have an incentive to recommend a rollover to you for the purpose of generating fee-based compensation rather than solely based on your needs. You are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by DWM. Many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of: 1. Leaving the funds in your employer's (former employer's) plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of these options has advantages and disadvantages and before making a change we encourage you to speak with your CPA and/or tax attorney. If you are considering rolling over your retirement funds to an IRA for us to manage here are a few points to consider before you do so: 1. Determine whether the investment options in your employer's retirement plan address your needs or whether you might want to consider other types of investments. a. Employer retirement plans generally have a more limited investment menu than IRAs. b. Employer retirement plans may have unique investment options not available to the public such as employer securities, or previously closed funds. 2. Your current plan may have lower fees than our fees a. If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your employer's retirement plan and how the costs of those share classes compare with those available in an IRA. b. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs of those products and services. 3. Our strategy may have higher risk than the option(s) provided to you in your plan. 4. Your current plan may also offer financial advice. 5. If you keep your assets titled in a 401k or retirement account, you could potentially delay your required minimum distribution beyond age 72. 6. Your 401k may offer more liability protection than a rollover IRA; each state may vary. a. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally protected from creditors in bankruptcies. However, there can be some exceptions to the general rules so you should consult with an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401k, but not from an IRA. 8. IRA assets can be accessed any time; however, distributions are subject to ordinary income tax Form ADV Part 2A/B Diastole Wealth Management, Inc. Page 26 of 33 ver. 1-08062025  and may also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability, higher education expenses or the purchase of a home. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire us as the manager and keep the assets titled in the plan name. It is important that you understand the differences between these types of accounts and to decide whether a rollover is best for you. Prior to proceeding, if you have questions contact your investment adviser representative, or call our main number as listed on the cover page of this brochure. Form ADV Part 2A/B Diastole Wealth Management, Inc. Page 27 of 33 ver. 1-08062025  Item 1. Cover Page Form ADV Part 2B: Brochure Supplement Last Updated: August 6, 2025 Diastole Wealth Management, Inc. 58 Boston Street Guilford, CT 06437 (203) 458-5220 www.dwinvest.com Supervised Persons: Elizabeth D. Eden Elizabeth E. Cook Mary L. O’Toole Jennifer L. O’Brien Eniko Mikle Barbara A. Buzzelli Ethan Eden Meredith Eden This brochure supplement provides information about the Supervised Persons listed above that supplement DWM’s brochure. You should have received a copy of that brochure. Please contact Meredith Eden at (203) 458-5220 and/or via email at meden@dwinvest.com if you did not receive DWM’s brochure or if you have any questions about the contents of this supplement. Additional information about DWM is also available on the SEC’s website at www.adviserinfo.sec.gov or its own website at www.dwinvest.com. Form ADV Part 2A/B Diastole Wealth Management, Inc. Page 28 of 33 ver. 1-08062025  Item 2. Educational Background and Experience Supervised Persons DWM requires certain licensing standards as well as a certain level of business experience for giving investment advice to clients. For example, all advisers must be professionals with relevant industry experience in order to adequately demonstrate a certain level of expertise in securities management and analysis. DWM requires that all investment adviser representatives maintain the minimum licensing qualifications in accordance with all federal, state, and self-regulatory organization (SRO) rules and regulations. Elizabeth D. Eden Founder, Principal, President, CEO Born 1955 Education BA Degree in English, Centre College (1977) Investment Management Program, The Wharton School (1994) Experience 1996 to Present – Diastole Wealth Management, Inc. 2008 to 2013 – ETC Brokerage Services, LLC (f/k/a Collective Financial, LLC) 2005 to Present – Eden Investment Partners, LLC 1984 to 1996 – Dean Witter, Senior VP and District Manager 1982 to 1984 – Shearson Lehman Bros, Investment Consultant Elizabeth E. Cook Principal Born 1958 Education BA Degree in History, Yale University (1980) BFA Degree in Painting, Lyme Academy College of Fine Arts (2012) MFA Degree in Fine Arts, School of Visual Arts (2014) Experience 1996 to Present – Diastole Wealth Management, Inc. 2008 to 2013 – ETC Brokerage Services, LLC 2005 to Present – Eden Investment Partners, LLC 1984 to 1996 – Dean Witter, Assistant Vice President Mary L. O’Toole, CFA Senior Financial Advisor Born 1960 Education Xavier University MBA, BA, Finance, International Affairs Experience 2009 - Present – Diastole Wealth Management, Inc. 2007 -2009 – Interocean Wealth Management LLC 2005 -2006 – Column Capital Advisors LLC Designations Chartered Financial Analyst (CFA) (1989) Form ADV Part 2A/B Diastole Wealth Management, Inc. Page 29 of 33 ver. 1-08062025  Jennifer L. O’Brien Senior Financial Advisor Born 1969 Education BS in Accounting, Salve Regina University (1991) Experience 2012-Present – Diastole Wealth Management, Inc. 2012-2013 – ETC Brokerage Services, LLC 2006 -2012- COO Investment Services Corp Eniko Mikle Senior Financial Advisor Born 1963 Education KLTE Gimnazium, Debrecen – Hungary (1982) Experience 2013 to Present – Diastole Wealth Management Inc. 2013 to 2013 – ETC Brokerage Services, LLC, Registered Representative 2008 to 2013 – Merrill Lynch Wealth Management, Senior Financial Advisor 2005 to 2008 – UBS Wealth Management, Financial Advisor Barbara A. Buzzelli Senior Financial Advisor Born 1959 Education BS in Business Management, Southern New Hampshire University (1981) Experience 2010-Present – Diastole Wealth Management, Inc. 2007-Present – William Pitt Sotheby’s International Realty 2006-2007 – East Lyme Board of Education 1999-2006 – Diastole Wealth Management, Inc. Ethan Eden Shareholder Born 1979 Education BA Degree in History, Yale University (2001) MBA, Cornell University (2007) Experience 2017 to Present – Managing Member of Digital Financial LLC 2010 to Present – Market76, Inc. 1996 to Present – Diastole Wealth Management, Inc. 2008 to 2012 – ETC Brokerage Services, LLC Form ADV Part 2A/B Diastole Wealth Management, Inc. Page 30 of 33 ver. 1-08062025  Meredith Eden Chief Operating Officer (COO)/Chief Compliance Officer (CCO) Born 1977 Education BA Degree; Trinity College (2000) Recent Experience 2000 to Present – Diastole Wealth Management, Inc. Use of Professional Designations Chartered Financial Analyst (CFA). The Chartered Financial Analyst (CFA) designation is a mark of distinction that is globally recognized by employers, investment professionals, and investors. Since it was first introduced in 1963, the Chartered Financial Analyst® designation, or CFA charter, has become one of the most respected and recognized investment credential in the world. To earn the CFA charter, one must have four years of qualified investment work experience; become a member of CFA Institute (the global association of investment professionals that administers the CFA charter), pledge to adhere to the CFA Institute Code of Ethics and Standards of Professional Conduct on an annual basis; apply for membership to a local CFA member society; and complete the CFA Program. The CFA Program is a globally recognized, graduate level curriculum that provides a strong foundation of the real-world investment analysis and portfolio management skills and practical knowledge needed in today’s investment industry. It also emphasizes the highest ethical and professional standards. The Program is organized into three levels, each culminating in a six-hour exam. CFA Program candidates report dedicating in excess of 300 hours of study per level. Completing the entire Program is a significant challenge that takes most candidates between two and five years. For more information, please visit www.cfainstitutue.org. Item 3. Disciplinary Information Criminal or Civil Action There are no disclosure events involving a criminal or civil action in a domestic, foreign, or military court of competent jurisdiction in which DWM or its personnel are involved. Administrative Proceeding (SEC/Federal/State) Regarding disclosure events involving an administrative proceeding before the SEC, on September 10, 2021, the Securities Exchange Commission ("SEC") issued a Settled Order ("Order") to which Diastole Wealth Management, Inc. ("DWM") and Elizabeth Eden, Co-Founder and Chief Compliance Officer ("Respondents"), consented without admitting or denying the findings of the Order to settle Case Number: 3-20534. The Order finds that the Respondents violated certain provisions of the Investment Advisers Act of 1940 and orders that: Respondents are censured, Respondents ordered to cease and desist from committing or causing any violations and any future violations of the Investment Advisers Act of 1940, DWM pay a civil penalty of $100,000 and Ms. Eden pay a civil penalty of $60,000, and Ms. Eden is limited in her activities from serving as a chief compliance officer. DWM agreed to engage an independent compliance consultant to review certain aspects of DWM's compliance program and make recommendations. On May 1, 2019, the SEC found that the Respondents did not adequately disclose certain conflicts of interest relating to the investments made by a private fund they advised, Eden Partners Absolute Growth Fund ("EPAG"), in notes issued by Market 76, Inc ("M76"), an affiliated company owned by Ms. Eden's son. According to the Order, a portion of the proceeds from the EPAG investment in M76 were transferred to DWM as repayment of loans that DWM previously had made to M76. EPAG has been reimbursed for that portion of EPAG's investment in M76 that was transferred to DWM. The Order also found that DWM did not timely deliver audited financial statements for EPAG to the Fund's investors. Form ADV Part 2A/B Diastole Wealth Management, Inc. Page 31 of 33 ver. 1-08062025  There are no other disclosure events involving an administrative proceeding before any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority in which DWM or its personnel are involved. Administrative Proceeding (SRO) There are no disclosure events involving A self-regulatory organization (SRO) proceeding in which DWM or its personnel are involved. Use of BrokerCheck If this supplement is delivered electronically, and any supervised person under the firm has a disciplinary history, the details of any disclosure may be found on either the Financial Industry Regulatory Authority’s (FINRA) BrokerCheck system (www.finra.org/brokercheck) or the IAPD (www.adviserinfo.sec.gov). There is no other proceeding in which a professional attainment, designation, or license of any of the supervised persons as part of this Brochure Supplement was revoked or suspended because of a violation of rules relating to professional conduct, nor were there any incidents where any of the supervised persons as part of this Brochure Supplement resigned (or otherwise relinquished his attainment, designation, or license) in anticipation of such a proceeding. Item 4. Other Business Activities Other Related Investment Business None of DWM’s supervised person(s) listed above is actively engaged in any investment-related business or occupation, including if the supervised person is registered, or has an application pending to register, as a broker-dealer, registered representative of a broker-dealer, futures commission merchant (“FCM”), commodity pool operator (“CPO”), commodity trading advisor (“CTA”), or an associated person of an FCM, CPO, or CTA. Insurance Business A select number of investment adviser representatives (“IARs”) as supervised persons of DWM (Elizabeth D. Eden and Jennifer L. O’Brien) are also licensed insurance agents, and in such capacity, may recommend, on a fully disclosed basis, the purchase of certain insurance-related products which may present a potential conflict of interest between DWM’s interests and those of its advisory clients. When acting in this capacity, such supervised persons may receive commissions for selling these products. However, clients are under no obligation to purchase products DWM or its management persons may recommend, or to purchase products or services through DWM or its management persons. Northcreek Funds As previously stated in Item 10 above, EPAG also has invested in a series of unaffiliated private equity funds, Northcreek Fund II, III, and IV. Additionally, EPAG has also invested in Northcreek Fund I for which Elizabeth Eden serves as one of the general partners and receives compensation in the amount of 30% of the total general partnership interest. Elizabeth Eden has decided not to receive this compensation directly and instead, assigns this compensation to the EPAG for the benefit of its limited partners. This presents a conflict of interest because as noted above DWM owns and has investments in, and is compensated by, EPAG. Therefore, DWM has a financial incentive to recommend EPAG to its clients. These conflicts are mitigated by DWM's fiduciary obligation to act in the best interest of clients, contractual limitations that govern DWM's activities as adviser or general partner, as applicable, and the requirement that DWM not to place its interests before clients' interests when managing EPAG. Clients who are investors in EPAG should refer to EPAG's offering documents for detailed disclosures. Form ADV Part 2A/B Diastole Wealth Management, Inc. Page 32 of 33 ver. 1-08062025  Item 5. Additional Compensation None of the supervised persons listed above as part of this Brochure Supplement receive any “economic benefit” as that term is defined (e.g., sales awards and other prizes) from a non-client for providing advisory services. Item 6. Supervision Designated Supervisor Meredith Eden is the designated supervisor for DWM responsible for providing supervisory oversight regarding DWM’s advisory business. Meredith Eden’s contact information is (203) 458-5220. All supervision is performed on a regular and continuous basis where transactional activity is reviewed and approved by Meredith Eden as well as a review of ongoing management of investment advice and financial planning services. Form ADV Part 2A/B Diastole Wealth Management, Inc. Page 33 of 33 ver. 1-08062025