ECHO45 ADVISORS LLC

Item 1: Cover Page Part 2A of Form ADV: Firm Brochure June 2, 2025 1802 Tice Valley Blvd Walnut Creek, CA 94595 www.echo45advisors.com Firm Contact: Dave Reichert Chief Compliance Officer This brochure provides information about the qualifications and business practices of Echo45 Advisors LLC. If clients have any questions about the contents of this brochure, please contact us at (877) 432-4645. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any State Securities Authority. Additional information about our firm is also available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD #307265. Please note that the use of the term “registered investment adviser” and description of our firm and/or our associates as “registered” does not imply a certain level of skill or training. Clients are encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise clients for more information on the qualifications of our firm and our employees.  Item 2: Material Changes Echo45 Advisors is required to make clients aware of information that has changed since the last annual update to the Firm Brochure (“Brochure”) and that may be important to them. Clients can then determine whether to review the brochure in its entirety or to contact us with questions about the changes. Since our last annual amendment filed on April 18, 2025 there have been no material changes. We have the following non-material changes to report: • Our firm now has a $100 minimum account size for new clients on our Auto Pilot program. ADV Part 2A – Firm Brochure Page 2 Echo45 Advisors LLC  Item 3: Table of Contents Item 1: Cover Page .................................................................................................................................... 1 Item 2: Material Changes ......................................................................................................................... 2 Item 3: Table of Contents ......................................................................................................................... 3 Item 4: Advisory Business ....................................................................................................................... 4 Item 5: Fees & Compensation ................................................................................................................. 8 Item 6: Performance-Based Fees & Side-By-Side Management ..................................................... 11 Item 7: Types of Clients & Account Requirements ........................................................................... 11 Item 8: Methods of Analysis, Investment Strategies & Risk of Loss .............................................. 12 Item 9: Disciplinary Information ......................................................................................................... 19 Item 10: Other Financial Industry Activities & Affiliations ............................................................ 19 Item 11: Code of Ethics, Participation or Interest in ........................................................................ 20 Item 12: Brokerage Practices ............................................................................................................... 21 Item 13: Review of Accounts or Financial Plans ............................................................................... 26 Item 14: Client Referrals & Other Compensation ............................................................................. 26 Item 15: Custody ...................................................................................................................................... 27 Item 16: Investment Discretion............................................................................................................ 28 Item 17: Voting Client Securities .......................................................................................................... 28 Item 18: Financial Information ............................................................................................................ 28 ADV Part 2A – Firm Brochure Page 3 Echo45 Advisors LLC  Item 4: Advisory Business Our firm is dedicated to providing individuals and other types of clients with a wide array of investment advisory services. Our firm is a limited liability company formed under the laws of the State of California in 2020 and has been in business as an investment adviser since that time. Our firm is wholly owned by the Jon Henderson Living Trust dated April 7, 2015. The purpose of this Brochure is to disclose the conflicts of interest associated with the investment transactions, compensation and any other matters related to investment decisions made by our firm or its representatives. As a fiduciary, it is our duty to always act in the client’s best interest. This is accomplished in part by knowing our client. Our firm has established a service-oriented advisory practice with open lines of communication for many different types of clients to help meet their financial goals while remaining sensitive to risk tolerance and time horizons. Working with clients to understand their investment objectives while educating them about our process, facilitates the kind of working relationship we value. Types of Advisory Services Offered Comprehensive Wealth Management: Our firm initially meets with the prospective client to understand their current financial situation, existing resources, financial goals, and risk tolerance. If our firm and the client agree to work together, we will have the client sign a Comprehensive Wealth Management Agreement. We will then present a personalized investment approach to the client and develop a portfolio consisting of securities such as individual stocks, bonds, ETFs, options, mutual funds and other public investments. Once the appropriate portfolio has been determined, portfolios are continuously and regularly monitored, and if necessary, rebalanced based upon the client’s individual needs, stated goals and objectives. Upon client request, our firm provides a summary of observations and recommendations for the planning or consulting aspects of this service. For certain clients, our firm may recommend and utilize the sub-advisory, separately managed account (“SMA”), and Turnkey Asset Management Program (“TAMP”) services of a third-party investment advisory firm or individual advisor (altogether, “Third Party Managers”) to aid in the implementation of an investment portfolio designed by our firm to meet the unique needs or complexities of that client. Before selecting a firm or individual, our firm will ensure that the chosen party is properly licensed or registered. Our firm will not offer advice on any specific securities or other investments in connection with this service. We will provide initial due diligence on third party money managers and ongoing reviews of their management of client accounts. In order to assist in the selection of a third-party money manager, our firm will gather client information pertaining to the client’s financial situation, investment objectives, and reasonable restrictions to be imposed upon the management of the account. Our firm will contact clients from time to time in order to review their financial situation and objectives; communicate information to third party money managers as warranted; and, assist the client in understanding and evaluating the services provided by the third-party money manager. Clients will be expected to notify our firm of any changes in their financial situation, investment objectives, or account restrictions that could affect their financial standing. ADV Part 2A – Firm Brochure Page 4 Echo45 Advisors LLC  Clients who participate in Comprehensive Wealth Management will also receive the services described under Financial Planning of Item 4 for no additional charge. Investment Management: Our firm initially meets with the prospective client to understand their current financial situation, existing resources, financial goals, and risk tolerance. If our firm and the client agree to work together, we will have the client sign an Investment Management Agreement. We will then present a personalized investment approach to the client and develop a portfolio consisting of securities such as individual stocks, bonds, ETFs, options, mutual funds and other public investments. Once the appropriate portfolio has been determined, portfolios are continuously and regularly monitored, and if necessary, rebalanced based upon the client’s individual needs, stated goals and objectives. Upon client request, our firm provides a summary of observations and recommendations for the planning or consulting aspects of this service. For certain clients, our firm may recommend and utilize the sub-advisory, separately managed account (“SMA”), and Turnkey Asset Management Program (“TAMP”) services of a third-party investment advisory firm or individual advisor (altogether, “Third Party Managers”) to aid in the implementation of an investment portfolio designed by our firm to meet the unique needs or complexities of that client. Before selecting a firm or individual, our firm will ensure that the chosen party is properly licensed or registered. Our firm will not offer advice on any specific securities or other investments in connection with this service. We will provide initial due diligence on third party money managers and ongoing reviews of their management of client accounts. In order to assist in the selection of a third-party money manager, our firm will gather client information pertaining to the client’s financial situation, investment objectives, and reasonable restrictions to be imposed upon the management of the account. Our firm will contact clients from time to time in order to review their financial situation and objectives; communicate information to third party money managers as warranted; and, assist the client in understanding and evaluating the services provided by the third-party money manager. Clients will be expected to notify our firm of any changes in their financial situation, investment objectives, or account restrictions that could affect their financial standing. No Financial Planning is offered under our Investment Management service. Retirement Plan Consulting: Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing, monitoring and reviewing their company's participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising may include: • • Establishing an Investment Policy Statement – Our firm may assist in the development of a statement that summarizes the investment goals and objectives along with the broad strategies to be employed to meet the objectives. Investment Options – Our firm will work with the Plan Sponsor to evaluate existing investment options and make recommendations for appropriate changes. ADV Part 2A – Firm Brochure Page 5 Echo45 Advisors LLC  • • Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation models to aid Participants in developing strategies to meet their investment objectives, time horizon, financial situation and tolerance for risk. Investment Monitoring – Our firm will monitor the performance of the investments and notify the client in the event of over/underperformance and in times of market volatility. • Participant Education – Our firm will provide opportunities to educate plan participants about their retirement plan offerings, different investment options, and general guidance on allocation strategies. In providing services for retirement plan consulting, our firm does not provide any advisory services with respect to the following types of assets: employer securities, real estate (excluding real estate funds and publicly traded REITS), participant loans, non-publicly traded securities or assets, other illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). All retirement plan consulting services shall be in compliance with the applicable state laws regulating retirement consulting services. This applies to client accounts that are retirement or other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointment to provide services to such accounts, our firm acknowledges its fiduciary standard within the meaning of Section 3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to the provision of services described therein. Financial Planning: Our firm provides a variety of standalone financial planning services to clients for the management of financial resources based upon an analysis of current situation, goals, and objectives. Financial planning services will typically involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning may encompass Investment Planning, Retirement Planning, Estate Planning, Charitable Planning, Education Planning, Corporate and Personal Tax Planning, Corporate Structure, Real Estate Analysis, Divorce Financial Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation, or Business and Personal Financial Planning. Written financial plans rendered to clients usually include general recommendations for a course of activity or specific actions to be taken by the clients. Implementation of the recommendations will be at the discretion of the client. Our firm provides clients with a summary of their financial situation, and observations for financial planning engagements. Assuming that all the information and documents requested from the client are provided promptly, plans or consultations are typically completed within 6 months of the client signing a contract with our firm. Estate Planning: Our firm offers third-party estate planning services provided by EncorEstate Plans. EncorEstate Plans is a non-affiliated third-party, and these services are offered in addition to our other advisory services. Echo45 will assist our clients with general information as it applies to reviews of existing plans, gathering information needed to provide outside firms in the creation of documents, and updating existing plans for clients. Our firm does not provide any legal advice, and all legal documents are completed by EncorEstate Plans or another third party. ADV Part 2A – Firm Brochure Page 6 Echo45 Advisors LLC  Auto Pilot: Our firm’s Auto Pilot service is provided through an online platform maintained by MTG, LLC dba Betterment Securities (“Betterment Securities”), which guides clients through the investment management process. With respect to this service, clients are required to use Betterment Securities as the custodian of their account assets. Betterment Securities is responsible for the execution of securities transactions and maintains custody of account assets. Clients authorize our firm to implement proprietary portfolio models offered by Betterment Securities or our firm. Clients complete a personal risk tolerance assessment and provide additional information about their financial goals through Betterment Securities’ online platform. Betterment Securities offers a High Yield Cash option or a model investment portfolio. Clients have the option to select Betterment Securities’ recommended portfolio model or permit our firm to select a portfolio model on their behalf. We generally create diversified model portfolios of investments consisting of low-cost exchange traded funds (“ETFs”), mutual funds, and other similar equity-related index funds. Clients can access their profile on Betterment Securities’ online platform and directly modify their risk preferences, investment objectives, investment size, and any other restrictions for their accounts. Betterment Securities automatically rebalances portfolio models in accordance with each portfolio model’s rebalancing parameters. We will periodically rebalance client model portfolios based upon the client’s individual needs, stated goals, and objectives. Echo45 Auto Pilot clients may also engage an Echo45 Financial Advisor who is a CERTIFIED FINANCIAL PLANNER™ for financial planning services for an additional fee. Tailoring of Advisory Services Our firm offers individualized investment advice to our Comprehensive Wealth Management, Investment Management, and Auto Pilot clients. General investment advice will be offered to our Retirement Plan Consulting or Financial Planning clients. Each Comprehensive Wealth Management, Investment Management, and Auto Pilot client may place reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account. Participation in Wrap Fee Programs Our firm does not offer or sponsor a wrap fee program. Regulatory Assets Under Management As of 12/31/2024, our firm managed $194,875,409 on a discretionary basis. ADV Part 2A – Firm Brochure Page 7 Echo45 Advisors LLC  Item 5: Fees & Compensation Compensation for Our Advisory Services Comprehensive Wealth Management: Assets Under Management Annual Percentage of Assets Charge First $1,000,000 Next $4,000,000 Next $5,000,000 Over $10,000,000 1.50% 1.00% 0.75% 0.65% Fees to be assessed will be outlined in the advisory agreement to be signed by the client. Our firm’s annualized fees are billed on a pro-rata basis monthly in advance based on the value of the account(s) on the last day of the previous month. Our firm bills on cash unless indicated otherwise in writing. Fees are generally not negotiable. In rare cases, our firm will agree to directly invoice. Fees will generally be deducted from client account(s). As part of this process, clients understand the following: a) The client’s independent custodian sends statements at least quarterly showing the market values for each security included in the assets and all account disbursements, including the amount of the advisory fees paid to our firm. b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our firm will send an invoice directly to the custodian. For assets held at a custodian that is not directly accessible by our firm, we may, but are not required to, manage these held away accounts using the Pontera Order Management System ("Pontera"). Pontera enables our firm to view and manage such assets. Our firm’s advisory fees for held away accounts will not be deducted directly from the held away accounts managed through Pontera. Clients will give written authorization to deduct the fee from another non-qualified account, in which case, the advisory fee would be deducted from this account each month. Fees will be based upon the client’s negotiated fee in accordance with our firm’s fee schedule and the client’s advisory agreement. Clients do not pay an additional fee for Pontera. If a Third Party Manager is selected to manage any portion of a client’s portfolio, the maximum annual fee charged by the Third Party Manager to the client will not exceed 1.25%. The Third Party Manager’s fee shall be separate from, and in addition to, the advisory fee charged by our firm. As such, the maximum combined advisory fee charged to clients by the Third Party Manager and our firm will not exceed 2.50%. Our firm debits our advisory fees as described in the executed advisory agreement between the client and our firm. Third Party Money Managers establish and maintain their own separate billing processes over which we have no control. They will typically bill clients directly and describe how this process works in their separate disclosure documents. The Third Party Managers that we recommend will not directly charge you a higher fee than they would have charged without us introducing you to them. ADV Part 2A – Firm Brochure Page 8 Echo45 Advisors LLC  Investment Management: Assets Under Management Annual Percentage of Assets Charge First $1,000,000 Next $4,000,000 Next $5,000,000 Over $10,000,000 1.00% 0.75% 0.50% 0.35% Fees to be assessed will be outlined in the advisory agreement to be signed by the client. Our firm’s annualized fees are billed on a pro-rata basis monthly in advance based on the value of the account(s) on the last day of the previous month. Our firm bills on cash unless indicated otherwise in writing. Fees are generally not negotiable. In rare cases, our firm will agree to directly invoice. Fees will generally be deducted from client account(s). As part of this process, clients understand the following: a) The client’s independent custodian sends statements at least quarterly showing the market values for each security included in the assets and all account disbursements, including the amount of the advisory fees paid to our firm. b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our firm will send an invoice directly to the custodian. For assets held at a custodian that is not directly accessible by our firm, we may, but are not required to, manage these held away accounts using the Pontera Order Management System ("Pontera"). Pontera enables our firm to view and manage such assets. Our firm’s advisory fees for held away accounts will not be deducted directly from the held away accounts managed through Pontera. Clients will give written authorization to deduct the fee from another non-qualified account, in which case, the advisory fee would be deducted from this account each month. Fees will be based upon the client’s negotiated fee in accordance with our firm’s fee schedule and the client’s advisory agreement. Clients do not pay an additional fee for Pontera. If a Third Party Manager is selected to manage any portion of a client’s portfolio, the maximum annual fee charged by the Third Party Manager to the client will not exceed 1.25%. The Third Party Manager’s fee shall be separate from, and in addition to, the advisory fee charged by our firm. As such, the maximum combined advisory fee charged to clients by the Third Party Manager and our firm will not exceed 2.50%. Our firm debits our advisory fees as described in the executed advisory agreement between the client and our firm. Third Party Money Managers establish and maintain their own separate billing processes over which we have no control. They will typically bill clients directly and describe how this process works in their separate disclosure documents. The Third Party Managers that we recommend will not directly charge you a higher fee than they would have charged without us introducing you to them. Retirement Plan Consulting: Our Retirement Plan Consulting services are billed a fee based on the percentage of Plan assets under management not to exceed 1.00%. The fee-paying arrangements will be determined on a case-by- case basis and will be detailed in the signed consulting agreement. ADV Part 2A – Firm Brochure Page 9 Echo45 Advisors LLC  Financial Planning: Our firm charges a project-based planning fee or recurring subscription-based fee for financial planning services. Recurring subscription-based fees may also be subject to a one-time initial payment at the onset of the subscription. The total estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of our engagement with the client. Flat fees will not exceed $20,000. The fee-paying arrangements will be determined on a case-by-case basis and will be detailed in the signed financial planning agreement. Our firm will not require a retainer exceeding $1,200 when services cannot be rendered within 6 months. Estate Planning: Our firm charges a project-based fee for Estate Planning Services offered through EncorEstate. This fee will not exceed $2,500 for any single estate plan. Households requiring multiple trusts may pay up to this amount per trust being created and the fee will be based on the scope and complexity of the services provided by Echo45 and EncorEstate. Our firm will not require a retainer exceeding $1,200 when services cannot be rendered within 6 months. Auto Pilot: The maximum total advisory fee charged for our Auto Pilot service will not exceed 0.50% of assets under management. The fee is split between our firm and Betterment Securities. Annualized fees are billed on a pro-rata basis monthly in arrears based on the value of the account(s) on the last day of the previous month. Fees are generally not negotiable and will generally be deducted from client account(s). As part of this process, clients understand the following: a) Betterment Securities sends statements at least quarterly showing the market values for each security included in the assets and all account disbursements, including the amount of the advisory fees paid to our firm and Betterment Securities. b) Clients will provide authorization permitting our firm and Betterment Securities to be directly paid by these terms. c) If our firm sends a copy of our invoice to the client, our invoice will include a disclosure urging the client to compare the information provided in our statement with those from Betterment Securities. Other Types of Fees & Expenses Clients may incur transaction fees for trades executed by their chosen custodian, via individual transaction charges on select investments. These transaction fees are separate from our firm’s advisory fees and will be disclosed by the chosen custodian. Charles Schwab & Co., Inc. (“Schwab”) does not charge transaction fees for U.S. listed equities and exchange traded funds. Clients may also pay holdings charges imposed by the chosen custodian for certain investments, charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses), initial or deferred sales charges, mutual fund sales loads, 12b-1 fees, surrender charges, variable annuity fees, IRA and qualified retirement plan fees, mark-ups and mark-downs, spreads paid to market makers, fees for trades executed away from custodian, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. Our firm does not receive a portion of these fees. ADV Part 2A – Firm Brochure Page 10 Echo45 Advisors LLC  Termination & Refunds Either party may terminate the advisory agreement signed with our firm for Comprehensive Wealth Management services by providing written notice to the other party at any time. Upon notice of termination, our firm will process a pro-rata refund of the unearned portion of the advisory fees charged in advance. Either party to a Retirement Plan Consulting Agreement may terminate at any time by providing written notice to the other party. Full refunds will only be made in cases where cancellation occurs within 5 business days of signing an agreement. After 5 business days from initial signing, either party must provide the other party 30 days written notice to terminate billing. Billing will terminate 30 days after receipt of termination notice. Clients will be charged on a pro-rata basis, which takes into account work completed by our firm on behalf of the client. Clients will incur charges for bona fide advisory services rendered up to the point of termination (determined as 30 days from receipt of said written notice) and such fees will be due and payable. Either party to a Financial Planning Agreement may terminate at any time by providing written notice to the other party. Clients will receive a pro-rata refund of any unearned fees based on the time and effort expended by our firm. Either party may terminate the advisory agreement signed with our firm for Auto Pilot service in writing at any time. Upon notice of termination, pro-rata advisory fees for services rendered to the point of termination will be charged. If advisory fees cannot be deducted, our firm may send an invoice for due advisory fees to the client. Commissionable Securities Sales Our firm and representatives do not sell securities for a commission in advisory accounts. Item 6: Performance-Based Fees & Side-By-Side Management Our firm does not charge performance-based fees. Item 7: Types of Clients & Account Requirements Our firm has the following types of clients: Individuals and High Net Worth Individuals • • Trusts, Trustees, Estates or Charitable Organizations • Professional Fiduciaries • Pension and Profit-Sharing Plans • Corporations, Limited Liability Companies and/or Other Business Types ADV Part 2A – Firm Brochure Page 11 Echo45 Advisors LLC  New clients are subject to the following minimum account values. These requirements are negotiable at the sole discretion of our firm. Auto Pilot requires a minimum account value of $100. Comprehensive Wealth Management requires a minimum account value of $500,000. Investment Management requires a minimum account value of $250,000. Item 8: Methods of Analysis, Investment Strategies & Risk of Loss Methods of Analysis We use the following methods of analysis in formulating our investment advice and/or managing client assets: Charting: In this type of technical analysis, our firm reviews charts of market and security activity in an attempt to identify when the market is moving up or down and to predict when how long the trend may last and when that trend might reverse. Cyclical Analysis: Statistical analysis of specific events occurring at a sufficient number of relatively predictable intervals that they can be forecasted into the future. Cyclical analysis asserts that cyclical forces drive price movements in the financial markets. Risks include that cycles may invert or disappear and there is no expectation that this type of analysis will pinpoint turning points, instead be used in conjunction with other methods of analysis. Fundamental Analysis: The analysis of a business's financial statements (usually to analyze the business's assets, liabilities, and earnings), health, and its competitors and markets. When analyzing a stock, futures contract, or currency using fundamental analysis there are two basic approaches one can use: bottom up analysis and top down analysis. The terms are used to distinguish such analysis from other types of investment analysis, such as quantitative and technical. Fundamental analysis is performed on historical and present data, but with the goal of making financial forecasts. There are several possible objectives: (a) to conduct a company stock valuation and predict its probable price evolution; (b) to make a projection on its business performance; (c) to evaluate its management and make internal business decisions; (d) and/or to calculate its credit risk.; and (e) to find out the intrinsic value of the share. When the objective of the analysis is to determine what stock to buy and at what price, there are two basic methodologies investors rely upon: (a) Fundamental analysis maintains that markets may misprice a security in the short run but that the "correct" price will eventually be reached. Profits can be made by purchasing the mispriced security and then waiting for the market to recognize its "mistake" and reprice the security.; and (b) Technical analysis maintains that all information is reflected already in the price of a security. Technical analysts analyze trends and believe that sentiment changes predate and predict trend changes. Investors' emotional responses to price movements lead to recognizable price chart patterns. Technical analysts also analyze historical trends to predict future price movement. Investors can use one or both of these different but complementary methods for stock picking. This presents a potential risk, as the price of a security ADV Part 2A – Firm Brochure Page 12 Echo45 Advisors LLC  can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Technical Analysis: A security analysis methodology for forecasting the direction of prices through the study of past market data, primarily price and volume. A fundamental principle of technical analysis is that a market's price reflects all relevant information, so their analysis looks at the history of a security's trading pattern rather than external drivers such as economic, fundamental and news events. Therefore, price action tends to repeat itself due to investors collectively tending toward patterned behavior – hence technical analysis focuses on identifiable trends and conditions. Technical analysts also widely use market indicators of many sorts, some of which are mathematical transformations of price, often including up and down volume, advance/decline data and other inputs. These indicators are used to help assess whether an asset is trending, and if it is, the probability of its direction and of continuation. Technicians also look for relationships between price/volume indices and market indicators. Technical analysis employs models and trading rules based on price and volume transformations, such as the relative strength index, moving averages, regressions, inter-market and intra-market price correlations, business cycles, stock market cycles or, classically, through recognition of chart patterns. Technical analysis is widely used among traders and financial professionals and is very often used by active day traders, market makers and pit traders. The risk associated with this type of analysis is that analysts use subjective judgment to decide which pattern(s) a particular instrument reflects at a given time and what the interpretation of that pattern should be. Qualitative Analysis: A securities analysis that uses subjective judgment based on unquantifiable information, such as management expertise, industry cycles, strength of research and development, and labor relations. Qualitative analysis contrasts with quantitative analysis, which focuses on numbers that can be found on reports such as balance sheets. The two techniques, however, will often be used together in order to examine a company's operations and evaluate its potential as an investment opportunity. Qualitative analysis deals with intangible, inexact concerns that belong to the social and experiential realm rather than the mathematical one. This approach depends on the kind of intelligence that machines (currently) lack, since things like positive associations with a brand, management trustworthiness, customer satisfaction, competitive advantage and cultural shifts are difficult, arguably impossible, to capture with numerical inputs. A risk in using qualitative analysis is that subjective judgment may prove incorrect. Quantitative Analysis: The use of models, or algorithms, to evaluate assets for investment. The process usually consists of searching vast databases for patterns, such as correlations among liquid assets or price-movement patterns (trend following or mean reversion). The resulting strategies may involve high-frequency trading. The results of the analysis are taken into consideration in the decision to buy or sell securities and in the management of portfolio characteristics. A risk in using quantitative analysis is that the methods or models used may be based on assumptions that prove to be incorrect. Sector Analysis: Sector analysis involves identification and analysis of various industries or economic sectors that are likely to exhibit superior performance. Academic studies indicate that the health of a stock's sector is as important as the performance of the individual stock itself. In other words, even the best stock located in a weak sector will often perform poorly because that sector is out of favor. Each industry has differences in terms of its customer base, market share among firms, industry growth, competition, regulation and business cycles. Learning how the industry operates provides a deeper understanding of a company's financial health. One method of analyzing a company's growth potential is examining whether the amount of customers in the overall market is ADV Part 2A – Firm Brochure Page 13 Echo45 Advisors LLC  expected to grow. In some markets, there is zero or negative growth, a factor demanding careful consideration. Additionally, market analysts recommend that investors should monitor sectors that are nearing the bottom of performance rankings for possible signs of an impending turnaround. Investment Strategies We Use We use the following strategies in managing client accounts, provided that such strategies are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations: Custom Indexing: “Custom indexing” or the process of replacing the performance of an index by purchasing the underlying shares. For example, if a client would like to replicate the risk and return profile of the S&P 500, instead of owning all 504 securities, we would seek to replicate the index with fewer securities, potentially as few as 100. First, we will decompose the S&P 500 into a series of factor exposures based on the underlying securities. Some examples of these factors include Market Capitalization, EPS Growth Rates, and Relative Strength. Then we look at the factor exposures of the securities currently held within the client’s portfolio – taking into account any unrealized gains or losses associated with each position. An optimization engine will build a portfolio of stocks from the S&P 500 and the client’s account to replicate (as close as possible) the factor exposure of the S&P 500 – given the constraint that we may only use 100 securities in this example. Custom Indexing provides unprecedented tax management capabilities as well as the ability to drill down into separate Environmental, Social and Governmental (E.S.G.) filters whereby each of our clients can work with us to build and own their own index free from investment in any industry they choose to avoid. Alternative Investments: Hedge funds, commodity pools, Real Estate Investment Trusts (“REITs”), Business Development Companies (“BDCs”), and other alternative investments involve a high degree of risk and can be illiquid due to restrictions on transfer and lack of a secondary trading market. They can be highly leveraged, speculative and volatile, and an investor could lose all or a substantial amount of an investment. Alternative investments may lack transparency as to share price, valuation and portfolio holdings. Complex tax structures often result in delayed tax reporting. Compared to mutual funds, hedge funds and commodity pools are subject to less regulation and often charge higher fees. Alternative investment managers typically exercise broad investment discretion and may apply similar strategies across multiple investment vehicles, resulting in less diversification. Asset Allocation: The implementation of an investment strategy that attempts to balance risk versus reward by adjusting the percentage of each asset in an investment portfolio according to the investor's risk tolerance, goals and investment time frame. Asset allocation is based on the principle that different assets perform differently in different market and economic conditions. A fundamental justification for asset allocation is the notion that different asset classes offer returns that are not perfectly correlated, hence diversification reduces the overall risk in terms of the variability of returns for a given level of expected return. Although risk is reduced as long as correlations are not perfect, it is typically forecast (wholly or in part) based on statistical relationships (like correlation and variance) that existed over some past period. Expectations for return are often derived in the same way. An asset class is a group of economic resources sharing similar characteristics, such as riskiness and return. There are many types of assets that may or may not be included in an asset allocation strategy. The "traditional" asset classes are stocks (value, dividend, growth, or sector-specific [or a "blend" of ADV Part 2A – Firm Brochure Page 14 Echo45 Advisors LLC  any two or more of the preceding]; large-cap versus mid-cap, small-cap or micro-cap; domestic, foreign [developed], emerging or frontier markets), bonds (fixed income securities more generally: investment-grade or junk [high-yield]; government or corporate; short-term, intermediate, long- term; domestic, foreign, emerging markets), and cash or cash equivalents. Allocation among these three provides a starting point. Usually included are hybrid instruments such as convertible bonds and preferred stocks, counting as a mixture of bonds and stocks. Other alternative assets that may be considered include: commodities: precious metals, nonferrous metals, agriculture, energy, others.; Commercial or residential real estate (also REITs); Collectibles such as art, coins, or stamps; insurance products (annuity, life settlements, catastrophe bonds, personal life insurance products, etc.); derivatives such as long-short or market neutral strategies, options, collateralized debt, and futures; foreign currency; venture capital; private equity; and/or distressed securities. There are several types of asset allocation strategies based on investment goals, risk tolerance, time frames and diversification. The most common forms of asset allocation are: strategic, dynamic, tactical, and core-satellite. • Strategic Asset Allocation: The primary goal of a strategic asset allocation is to create an asset mix that seeks to provide the optimal balance between expected risk and return for a long- term investment horizon. Generally speaking, strategic asset allocation strategies are agnostic to economic environments, i.e., they do not change their allocation postures relative to changing market or economic conditions. • Dynamic Asset Allocation: Dynamic asset allocation is similar to strategic asset allocation in that portfolios are built by allocating to an asset mix that seeks to provide the optimal balance between expected risk and return for a long-term investment horizon. Like strategic allocation strategies, dynamic strategies largely retain exposure to their original asset classes; however, unlike strategic strategies, dynamic asset allocation portfolios will adjust their postures over time relative to changes in the economic environment. • Tactical Asset Allocation: Tactical asset allocation is a strategy in which an investor takes a more active approach that tries to position a portfolio into those assets, sectors, or individual stocks that show the most potential for perceived gains. While an original asset mix is formulated much like strategic and dynamic portfolio, tactical strategies are often traded more actively and are free to move entirely in and out of their core asset classes • Core-Satellite Asset Allocation: Core-Satellite allocation strategies generally contain a 'core' strategic element making up the most significant portion of the portfolio, while applying a dynamic or tactical 'satellite' strategy that makes up a smaller part of the portfolio. In this way, core-satellite allocation strategies are a hybrid of the strategic and dynamic/tactical allocation strategies mentioned above. Digital Assets: We may recommend investment in digital currency products. These products may be direct coin ownership through a Separately Managed Account (“SMA”) or an Exchange Traded Fund (“ETF”) which pools capital together to purchase holdings of digital currencies or derivatives based on their value. Such products are extremely volatile and are suitable only as a means of diversification for investors with high risk tolerances. Duration Constraints: Our firm adheres to a discipline of generally maintaining duration based on expected market conditions in order to limit exposure to market risk. Our portfolio management team rebalances client portfolios to their current duration targets on a periodic basis. The risk of constraining duration is that the client may not participate fully in a large rally in bond prices. Fixed Income: Fixed income is a type of investing or budgeting style for which real return rates or periodic income is received at regular intervals and at reasonably predictable levels. Fixed income is ADV Part 2A – Firm Brochure Page 15 Echo45 Advisors LLC  often used in greater proportions by conservative investors, who may be retired individuals or individuals who rely on their investments to provide a regular, stable income stream, as well as by many investors for diversification and risk management. This demographic tends to invest in fixed- income investments because of the reliable returns they offer. Fixed-income investors who live on set amounts of periodically paid income face the risk of inflation eroding their spending power. Some examples of fixed-income investments include treasuries, money market instruments, corporate bonds, asset-backed securities, municipal bonds and international bonds. The primary risk associated with fixed-income investments is the borrower defaulting on his payment. Other considerations include exchange rate risk for international bonds and interest rate risk for longer- dated securities. The most common type of fixed-income security is a bond. Bonds are issued by federal governments, local municipalities and major corporations. Fixed-income securities are recommended for investors seeking a diverse portfolio; however, the percentage of the portfolio dedicated to fixed income depends on your own personal investment style. There is also an opportunity to diversify the fixed-income component of a portfolio. Riskier fixed-income products, such as junk bonds and longer-dated products, should comprise a lower percentage of your overall portfolio. The interest payment on fixed-income securities is considered regular income and is determined based on the creditworthiness of the borrower and current market rates. In general, bonds and fixed- income securities with longer-dated maturities pay a higher rate, also referred to as the coupon rate, because they are considered riskier. The longer the security is on the market, the more time it has to lose its value and/or default. At the end of the bond term, or at bond maturity, the borrower returns the amount borrowed, also referred to as the principal or par value. Long-Term Purchases: Our firm may buy securities for your account and hold them for a relatively long time (more than a year) in anticipation that the security’s value will appreciate over a long horizon. The risk of this strategy is that our firm could miss out on potential short-term gains that could have been profitable to your account, or it’s possible that the security’s value may decline sharply before our firm makes a decision to sell. Options: An option is a financial derivative that represents a contract sold by one party (the option writer) to another party (the option holder, or option buyer). The contract offers the buyer the right, but not the obligation, to buy or sell a security or other financial asset at an agreed-upon price (the strike price) during a certain period of time or on a specific date (exercise date). Options are extremely versatile securities. Traders use options to speculate, which is a relatively risky practice, while hedgers use options to reduce the risk of holding an asset. In terms of speculation, option buyers and writers have conflicting views regarding the outlook on the performance of a: • Call Option: Call options give the option to buy at certain price, so the buyer would want the stock to go up. Conversely, the option writer needs to provide the underlying shares in the event that the stock's market price exceeds the strike due to the contractual obligation. An option writer who sells a call option believes that the underlying stock's price will drop relative to the option's strike price during the life of the option, as that is how he will reap maximum profit. This is exactly the opposite outlook of the option buyer. The buyer believes that the underlying stock will rise; if this happens, the buyer will be able to acquire the stock for a lower price and then sell it for a profit. However, if the underlying stock does not close above the strike price on the expiration date, the option buyer would lose the premium paid for the call option. ADV Part 2A – Firm Brochure Page 16 Echo45 Advisors LLC  • Put Option: Put options give the option to sell at a certain price, so the buyer would want the stock to go down. The opposite is true for put option writers. For example, a put option buyer is bearish on the underlying stock and believes its market price will fall below the specified strike price on or before a specified date. On the other hand, an option writer who sells a put option believes the underlying stock's price will increase about a specified price on or before the expiration date. If the underlying stock's price closes above the specified strike price on the expiration date, the put option writer's maximum profit is achieved. Conversely, a put option holder would only benefit from a fall in the underlying stock's price below the strike price. If the underlying stock's price falls below the strike price, the put option writer is obligated to purchase shares of the underlying stock at the strike price. The potential risks associated with these transactions are that (1) all options expire. The closer the option gets to expiration, the quicker the premium in the option deteriorates; and (2) Prices can move very quickly. Depending on factors such as time until expiration and the relationship of the stock price to the option’s strike price, small movements in a stock can translate into big movements in the underlying options. Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. While the stock market may increase and the account(s) could enjoy a gain, it is also possible that the stock market may decrease and the account(s) could suffer a loss. It is important that clients understand the risks associated with investing in the stock market, and that their assets are appropriately diversified in investments. Clients are encouraged to ask our firm any questions regarding their risk tolerance. Capital Risk: Capital risk is one of the most basic, fundamental risks of investing; it is the risk that you may lose 100% of your money. All investments carry some form of risk and the loss of capital is generally a risk for any investment instrument. Company Risk: When investing in stock positions, there is always a certain level of company or industry specific risk that is inherent in each investment. This is also referred to as unsystematic risk and can be reduced through appropriate diversification. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. For example, if a company’s employees go on strike or the company receives unfavorable media attention for its actions, the value of the company may be reduced. Digital Assets: Digital assets are extremely volatile and are suitable only as a means of diversification for investors with high risk tolerances. Digital assets can experience dramatic price swings leading to potential losses. Additionally, digital assets generally lack the regulatory protections that other asset classes may be subject to. Legislative and regulatory changes may adversely affect the use, transfer, exchange, and value of digital assets. Economic Risk: The prevailing economic environment is important to the health of all businesses. Some companies, however, are more sensitive to changes in the domestic or global economy than others. These types of companies are often referred to as cyclical businesses. Countries in which a large portion of businesses are in cyclical industries are thus also very economically sensitive and carry a higher amount of economic risk. If an investment is issued by a party located in a country that experiences wide swings from an economic standpoint or in situations where certain elements of an investment instrument are hinged on dealings in such countries, the investment instrument will generally be subject to a higher level of economic risk. ADV Part 2A – Firm Brochure Page 17 Echo45 Advisors LLC  Equity (Stock) Market Risk: Common stocks are susceptible to general stock market fluctuations and, volatile increases and decreases in value as market confidence in and perceptions of their issuers change. If you held common stock, or common stock equivalents, of any given issuer, you would generally be exposed to greater risk than if you held preferred stocks and debt obligations of the issuer. ETF & Mutual Fund Risk: When investing in an ETF or mutual fund, you will bear additional expenses based on your pro rata share of the ETF’s or mutual fund’s operating expenses, including the potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities, the ETF, or mutual fund holds. Clients will also incur brokerage costs when purchasing ETFs. Financial Risk: Financial risk is represented by internal disruptions within an investment or the issuer of an investment that can lead to unfavorable performance of the investment. Examples of financial risk can be found in cases like Enron or many of the dot com companies that were caught up in a period of extraordinary market valuations that were not based on solid financial footings of the companies. Fixed Income Securities Risk: Typically, the values of fixed-income securities change inversely with prevailing interest rates. Therefore, a fundamental risk of fixed-income securities is interest rate risk, which is the risk that their value will generally decline as prevailing interest rates rise, which may cause your account value to likewise decrease, and vice versa. How specific fixed income securities may react to changes in interest rates will depend on the specific characteristics of each security. Fixed-income securities are also subject to credit risk, prepayment risk, valuation risk, and liquidity risk. Credit risk is the chance that a bond issuer will fail to pay interest and principal in a timely manner, or that negative perceptions of the issuer’s ability to make such payments will cause the price of a bond to decline. Inflation Risk: Inflation risk involves the concern that in the future, your investment or proceeds from your investment will not be worth what they are today. Throughout time, the prices of resources and end-user products generally increase and thus, the same general goods and products today will likely be more expensive in the future. The longer an investment is held, the greater the chance that the proceeds from that investment will be worth less in the future than what they are today. Said another way, a dollar tomorrow will likely get you less than what it can today. Interest Rate Risk: Certain investments involve the payment of a fixed or variable rate of interest to the investment holder. Once an investor has acquired or has acquired the rights to an investment that pays a particular rate (fixed or variable) of interest, changes in overall interest rates in the market will affect the value of the interest-paying investment(s) they hold. In general, changes in prevailing interest rates in the market will have an inverse relationship to the value of existing, interest paying investments. In other words, as interest rates move up, the value of an instrument paying a particular rate (fixed or variable) of interest will go down. The reverse is generally true as well. Market Risk: The value of your portfolio may decrease if the value of an individual company or multiple companies in the portfolio decreases or if our belief about a company’s intrinsic worth is incorrect. Further, regardless of how well individual companies perform, the value of your portfolio could also decrease if there are deteriorating economic or market conditions. It is important to understand that the value of your investment may fall, sometimes sharply, in response to changes in the market, and you could lose money. Investment risks include price risk as may be observed by a ADV Part 2A – Firm Brochure Page 18 Echo45 Advisors LLC  drop in a security’s price due to company specific events (e.g. earnings disappointment or downgrade in the rating of a bond) or general market risk (e.g. such as a “bear” market when stock values fall in general). For fixed-income securities, a period of rising interest rates could erode the value of a bond since bond values generally fall as bond yields go up. Past performance is not a guarantee of future returns. Options Risk: Options on securities may be subject to greater fluctuations in value than an investment in the underlying securities. Additionally, options have an expiration date, which makes them “decay” in value over the amount of time they are held and can expire worthless. Purchasing and writing put and call options are highly specialized activities and entail greater than ordinary investment risks. Past Performance: Charting and technical analysis are often used interchangeably. Technical analysis generally attempts to forecast an investment’s future potential by analyzing its past performance and other related statistics. In particular, technical analysis often times involves an evaluation of historical pricing and volume of a particular security for the purpose of forecasting where future price and volume figures may go. As with any investment analysis method, technical analysis runs the risk of not knowing the future and thus, investors should realize that even the most diligent and thorough technical analysis cannot predict or guarantee the future performance of any particular investment instrument or issuer thereof. Strategy Risk: There is no guarantee that the investment strategies discussed herein will work under all market conditions and each investor should evaluate his/her ability to maintain any investment he/she is considering in light of his/her own investment time horizon. Investments are subject to risk, including possible loss of principal. Description of Material, Significant or Unusual Risks Our firm generally invests client cash balances in money market funds, FDIC Insured Certificates of Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, our firm tries to achieve the highest return on client cash balances through relatively low-risk conservative investments. In most cases, at least a partial cash balance will be maintained in a money market account so that our firm may debit advisory fees for our services related to our Comprehensive Wealth Management service, as applicable. Item 9: Disciplinary Information There are no legal or disciplinary events that are material to the evaluation of our advisory business or the integrity of our management. Item 10: Other Financial Industry Activities & Affiliations Our firm has no other financial industry activities and affiliations to disclose. ADV Part 2A – Firm Brochure Page 19 Echo45 Advisors LLC  Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our clients at all times. Our fiduciary duty is the underlying principle for our firm’s Code of Ethics, which includes procedures for personal securities transaction and insider trading. Our firm requires all representatives to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws at all times. Upon employment with our firm, and at least annually thereafter, all representatives of our firm will acknowledge receipt, understanding and compliance with our firm’s Code of Ethics. Our firm and representatives must conduct business in an honest, ethical, and fair manner and avoid all circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure is provided to give all clients a summary of our Code of Ethics. If a client or a potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon request. Our firm recognizes that the personal investment transactions of our representatives demands the application of a Code of Ethics with high standards and requires that all such transactions be carried out in a way that does not endanger the interest of any client. At the same time, our firm also believes that if investment goals are similar for clients and for our representatives, it is logical, and even desirable, that there be common ownership of some securities. In order to prevent conflicts of interest, our firm has established procedures for transactions effected by our representatives for their personal accounts1. In order to monitor compliance with our personal trading policy, our firm has pre-clearance requirements and a quarterly securities transaction reporting system for all of our representatives. Neither our firm nor a related person recommends, buys or sells for client accounts, securities in which our firm or a related person has a material financial interest without prior disclosure to the client. Related persons of our firm may buy or sell securities and other investments that are also recommended to clients. In order to minimize this conflict of interest, our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. Likewise, related persons of our firm buy or sell securities for themselves at or about the same time they buy or sell the same securities for client accounts. In order to minimize this conflict of interest, our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. Further, our related persons will refrain from buying or selling the same securities prior to buying or selling for our clients in the same day unless included in a block trade. 1 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse, his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our associate controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or indirect beneficial interest in. ADV Part 2A – Firm Brochure Page 20 Echo45 Advisors LLC  Item 12: Brokerage Practices Selecting a Brokerage Firm While our firm does not maintain physical custody of client assets, we are deemed to have custody of certain client assets if given the authority to withdraw assets from client accounts (see Item 15 Custody, below). Client assets must be maintained by a qualified custodian. Our firm seeks to recommend a custodian who will hold client assets and execute transactions on terms that are overall most advantageous when compared to other available providers and their services. The factors considered, among others, are these: • Timeliness of execution • Timeliness and accuracy of trade confirmations • Research services provided • Ability to provide investment ideas • Execution facilitation services provided • Record keeping services provided • Custody services provided • Frequency and correction of trading errors • Ability to access a variety of market venues • Expertise as it relates to specific securities • Financial condition • Business reputation • Quality of services With this in consideration, our firm has arrangements with Altruist Financial LLC (“Altruist”), Charles Schwab & Co., Inc. (“Schwab”) and MTG, LLC dba Betterment Securities (“Betterment Securities”). Altruist, Schwab, and Betterment Securities are independent [and unaffiliated] SEC-registered broker-dealers. Altruist, Schwab, and Betterment Securities offer services to independent investment advisers which includes custody of securities, trade execution, clearance and settlement of transactions. Altruist, Schwab, and Betterment Securities enable us to obtain many no-load mutual funds without transaction charges and other no-load funds at nominal transaction charges. Schwab does not charge client accounts separately for custodial services. Client accounts will be charged transaction fees, commissions or other fees on trades that are executed or settle into the client’s custodial account. Transaction fees are negotiated with Schwab and are generally discounted from customary retail commission rates. This benefits clients because the overall fee paid is often lower than would be otherwise. Schwab may make certain research and brokerage services available at no additional cost to our firm. Altruist Financial, LLC Echo45 offers investment advisory services through the custodial platform offered by Altruist Financial LLC (“Altruist”), an unaffiliated SEC-registered broker-dealer and FINRA/SIPC member. Custody, clearing, and execution services are provided by Altruist Financial LLC as a self-clearing broker-dealer. Echo45’s clients establish brokerage accounts through Altruist. Echo45 maintains an institutional relationship with Altruist whereby Altruist provides certain to Echo45, including a fully digital account opening process, a variety of available investments, and integration with software ADV Part 2A – Firm Brochure Page 21 Echo45 Advisors LLC  tools that can benefit Echo45 and its clients. Echo45 is not affiliated with Altruist. Altruist does not supervise Echo45, its agents, activities, or its regulatory compliance. Echo45 participates in the Model Marketplace of Altruist LLC, an SEC-registered investment adviser and affiliate of Altruist Financial LLC. Through the Model Marketplace, Echo45 has access to model portfolios including Altruist LLC-generated portfolios and Third-Party portfolios, to assist it in managing or advising Echo45 client accounts. Echo45 also has the ability to create custom model portfolios and has access to tax management tools for use with Altruist LLC-generated portfolios, Third-Party Portfolios, and custom model portfolios, to assist Echo45 in managing or advising its clients’ accounts. Altruist LLC’s Model Marketplace fees and tax management tool fees – each of which range between 0.00% and 1.00% and are listed in the Altruist LLC Fee Schedule available at altruist.com/legal – are passed through to and debited from clients’ accounts according to the instruction of Echo45. Altruist LLC and its affiliates do not act as investment advisers or fiduciary to Echo45 clients. Echo45 is responsible for suitability of all investment decisions and transactions for client accounts subscribed to model portfolios though the Model Marketplace. Charles Schwab & Co., Inc Schwab Advisor Services is Charles Schwab & Co., Inc’s (“Schwab”) business serving independent investment advisory firms like our firm. They provide our firm and clients with access to its institutional brokerage – trading, custody, reporting and related services – many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help manage or administer our client accounts while others help manage and grow our business. Schwab’s support services are generally available on an unsolicited basis (our firm does not have to request them) and at no charge to our firm. The availability of Schwab’s products and services is not based on the provision of particular investment advice, such as purchasing particular securities for clients. Here is a more detailed description of Schwab’s support services: Services that Benefit Clients 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 our firm might not otherwise have access or that would require a significantly higher minimum initial investment by firm clients. Schwab’s services described in this paragraph generally benefit clients and their accounts. Services that May Not Directly Benefit Clients Schwab also makes available other products and services that benefit our firm but may not directly benefit clients or their accounts. These products and services assist in managing and administering our client accounts. They include investment research, both Schwab’s and that of third parties. This research may be used to service all or some substantial number of client accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • provides access to client account data (such as duplicate trade confirmations and account statements); facilitates trade execution and allocate aggregated trade orders for multiple client accounts; • • provides pricing and other market data; • facilitates payment of our fees from our clients’ accounts; and ADV Part 2A – Firm Brochure Page 22 Echo45 Advisors LLC  • assists with back-office functions, recordkeeping and client reporting; • offers UPS and other discounts; • provide referrals to our firm. Services that Generally Benefit Only Our Firm Schwab also offers other services intended to help manage and further develop our business enterprise. These services include: technology, compliance, legal, and business consulting; • educational conferences and events; • • publications and conferences on practice management and business succession; and • access to employee benefits providers, human capital consultants and insurance providers. Schwab may provide some of these services itself. In other cases, Schwab will arrange for third-party vendors to provide the services to our firm. Schwab may also discount or waive fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide our firm with other benefits, such as occasional business entertainment for our personnel. Our Interest in Schwab’s Services The availability of these services from Schwab benefits our firm because our firm does not have to produce or purchase them. Our firm does not have to pay for these services, and they are not contingent upon committing any specific amount of business to Schwab in trading commissions or assets in custody. In light of our arrangements with Schwab, a conflict of interest exists as our firm may have incentive to require that clients maintain their accounts with Schwab based on our interest in receiving Schwab’s services that benefit our firm rather than based on client interest in receiving the best value in custody services and the most favorable execution of transactions. As part of our fiduciary duty to our clients, our firm will endeavor at all times to put the interests of our clients first. Clients should be aware, however, that the receipt of economic benefits by our firm or our related persons creates a potential conflict of interest and may indirectly influence our firm’s choice of Schwab as a custodial recommendation. Our firm examined this potential conflict of interest when our firm chose to recommend Schwab and have determined that the recommendation is in the best interest of our firm’s clients and satisfies our fiduciary obligations, including our duty to seek best execution. Our clients may pay a transaction fee or commission to Schwab that is higher than another qualified broker dealer might charge to effect the same transaction where our firm determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services provided to the client as a whole. Betterment Securities Clients subscribing to our Auto Pilot service are required to use Betterment Securities as the custodian of their account assets. Betterment Securities serves as broker-dealer to Betterment for Advisors, an investment and advice platform serving independent investment advisory firms like us (“Betterment for Advisors”). Betterment Securities does not charge clients separately for custody/brokerage services, but is compensated as part of the Betterment for Advisors platform fee, ADV Part 2A – Firm Brochure Page 23 Echo45 Advisors LLC  which is charged for a suite of platform services, including custody, brokerage, and sub-advisory services provided by Betterment and access to the Betterment for Advisors platform. The platform fee is an asset-based fee charged as a percentage of assets in the client’s Betterment account. Clients utilizing the Betterment for Advisors platform may pay a higher aggregate fee than if the investment management, brokerage, and other platform services are purchased separately. Nonetheless, for those clients participating in the Betterment for Advisors platform, we have determined that having Betterment Securities execute trades is consistent with our duty to seek “best execution” of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. Betterment for Advisors also makes available various support services which may not be available to Betterment’s retail customers. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Betterment for Advisors’ support services are generally available on an unsolicited basis (we don’t have to request them) and at no charge to us. Following is a more detailed description of Betterment for Advisors’ support services: Services that Benefit Clients Betterment for Advisors includes access to a globally diversified, low-cost portfolio of ETFs, execution of securities transactions, and custody of client assets through Betterment Securities. In addition, a series of model portfolios created by third-party providers are also available on the platform. Betterment Securities’ services described in this paragraph generally benefit you and your account. Services that May Not Directly Benefit Clients Betterment for Advisors also makes available to us other products and services that benefit us, but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts, such as software and technology that may: • Assist with back-office functions, recordkeeping, and client reporting of our clients’ accounts. • Provide access to client account data (such as duplicate trade confirmations and account statements). • Provide pricing and other market data. Services that Generally Benefit Only Our Firm By using Betterment for Advisors, we may be offered other services intended to help us manage and further develop our business enterprise. These services include: • Consulting (including through webinars) on technology and business needs. • Access to publications and conferences on practice management and business succession. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including the value of research provided, execution capability, commission rates, and responsiveness. Although our firm will seek competitive rates, to the benefit of all clients, our firm may not necessarily obtain the lowest possible commission rates for specific client account transactions. ADV Part 2A – Firm Brochure Page 24 Echo45 Advisors LLC  Client Brokerage Commissions Altruist, Schwab, and Betterment do not make client brokerage commissions generated by client transactions available for our firm’s use. Client Transactions in Return for Soft Dollars Our firm does not direct client transactions to a particular broker-dealer in return for soft dollar benefits. Brokerage for Client Referrals Our firm does not receive brokerage for client referrals. Directed Brokerage Neither our firm nor any of our firm’s representatives have discretionary authority in making the determination of the brokers-dealers and/or custodians with whom orders for the purchase or sale of securities are placed for execution, and the commission rates at which such securities transactions are effected. Our firm routinely recommends that clients direct us to execute through a specified broker-dealer. Special Considerations for ERISA Clients A retirement or ERISA plan client may direct all or part of portfolio transactions for its account through a specific broker or dealer in order to obtain goods or services on behalf of the plan. Such direction is permitted provided that the goods and services provided are reasonable expenses of the plan incurred in the ordinary course of its business for which it otherwise would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the plan. Consequently, our firm will request that plan sponsors who direct plan brokerage provide us with a letter documenting that this arrangement will be for the exclusive benefit of the plan. Client-Directed Brokerage Our firm allows clients to direct brokerage outside our recommendation. Our firm may be unable to achieve the most favorable execution of client transactions. Client directed brokerage may cost clients more money. For example, in a directed brokerage account, clients may pay higher brokerage commissions because our firm may not be able to aggregate orders to reduce transaction costs, or clients may receive less favorable prices. Aggregation of Purchase or Sale Our firm provides investment management services for various clients. There are occasions on which portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same security for numerous accounts served by our firm, which involve accounts with similar investment ADV Part 2A – Firm Brochure Page 25 Echo45 Advisors LLC  objectives. Although such concurrent authorizations potentially could be either advantageous or disadvantageous to any one or more particular accounts, they are affected only when our firm believes that to do so will be in the best interest of the effected accounts. When such concurrent authorizations occur, the objective is to allocate the executions in a manner which is deemed equitable to the accounts involved. In any given situation, our firm attempts to allocate trade executions in the most equitable manner possible, taking into consideration client objectives, current asset allocation and availability of funds using price averaging, proration and consistently non-arbitrary methods of allocation. Item 13: Review of Accounts or Financial Plans Our management personnel or financial advisors review accounts on at least an annual basis for our Comprehensive Wealth Management clients. The nature of these reviews is to learn whether client accounts are in line with their investment objectives, appropriately positioned based on market conditions, and investment policies, if applicable. We provide quarterly performance reports to Comprehensive Wealth Management clients. Verbal reports to clients take place on at least an annual basis when our Comprehensive Wealth Management clients are contacted. Our management personnel and/or financial advisors review accounts on at least an annual basis for our Auto Pilot clients. The nature of these reviews is to learn whether client accounts are in line with their investment objectives, appropriately positioned based on market conditions, and investment policies, if applicable. Our firm does not provide written reports to clients, unless asked to do so. Our firm may review client accounts more frequently than described above. Among the factors which may trigger an off-cycle review are major market or economic events, the client’s life events, requests by the client, etc. Retirement Plan Consulting clients receive reviews of their retirement plans for the duration of the service. Our firm also provides ongoing services where clients are met with upon their request to discuss updates to their plans, changes in their circumstances, etc. Retirement Plan Consulting clients do not receive written or verbal updated reports regarding their plans unless they choose to engage our firm for ongoing services. Financial Planning clients receive reviews of their plans during the duration of their agreement’s term. Former Financial Planning clients do not receive written or verbal updated reports regarding their financial plans unless they separately engage our firm for additional services. Item 14: Client Referrals & Other Compensation Altruist Financial LLC, Charles Schwab & Co., Inc. & Betterment Securities Our firm receives economic benefits from Altruist, Schwab, and Betterment Securities in the form of the support products and services made available to our firm and other independent investment advisors that have their clients maintain accounts on their custodial platforms. These products and services, how they benefit our firm, and the related conflicts of interest are described above (see Item ADV Part 2A – Firm Brochure Page 26 Echo45 Advisors LLC  12 – Brokerage Practices). The availability of their products and services is not based on our firm giving particular investment advice, such as buying particular securities for our clients. Echo45 Tax & Estate Echo45 Tax & Estate is a separate entity that shares common ownership and control with Echo45 Advisors. While no referral fees are paid for one entity to refer a client to the other, each entity stands to benefit financially from clients being referred to it by the other entity. Item 15: Custody Deduction of Advisory Fees: While our firm does not maintain physical custody of client assets (which are maintained by a qualified custodian, as discussed above), we are deemed to have custody of certain client assets if given the authority to withdraw assets from client accounts, as further described below under “Third Party Money Movement.” All our clients receive account statements directly from their qualified custodian(s) at least quarterly upon opening of an account. We urge our clients to carefully review these statements. Additionally, if our firm decides to send its own account statements to clients, such statements will include a legend that recommends the client compare the account statements received from the qualified custodian with those received from our firm. Third Party Money Movement: On February 21, 2017, the SEC issued a no‐action letter (“Letter”) with respect to Rule 206(4)‐2 (“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client funds to a third party under a standing letter of instruction (“SLOA”) is deemed to have custody. As such, our firm has adopted the following safeguards in conjunction with Schwab: • The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. • The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. • The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization and provides a transfer of funds notice to the client promptly after each transfer. • The client has the ability to terminate or change the instruction to the client’s qualified custodian. • The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction. • The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. ADV Part 2A – Firm Brochure Page 27 Echo45 Advisors LLC  The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Clients are encouraged to raise any questions with us about the custody, safety or security of their assets and our custodial recommendations. Item 16: Investment Discretion Clients have the option of providing our firm with investment discretion on their behalf, pursuant to an executed investment advisory client agreement. By granting investment discretion, our firm is authorized to execute securities transactions, determine which securities are bought and sold, and the total amount to be bought and sold. Should clients grant our firm non-discretionary authority, our firm would be required to obtain the client’s permission prior to effecting securities transactions. Limitations may be imposed by the client in the form of specific constraints on any of these areas of discretion with our firm’s written acknowledgement. Item 17: Voting Client Securities Our firm only votes client proxies on assets custodied by Charles Schwab & Co. when authorized to do so in writing by a Comprehensive Wealth Management client or Investment Management client. Our firm does not vote proxies for other service levels or for assets held at any other custodian. Our firm understands our duty to vote client proxies and to do so in the best interest of our clients. Furthermore, it is understood that any material conflicts between our interests and those of our clients with regard to proxy voting must be resolved before proxies are voted. Our firm subscribes to a proxy monitor and voting agent service offered by Broadridge Investor Communication Solutions, Inc. (“Broadridge”). Our firm will generally vote in accordance with the board’s recommendations but may vote in a different fashion on particular votes if our firm determines that such actions are in the best interest of our clients. Where applicable, our firm will consider any specific voting guidelines designated in writing by a client. Clients may request a copy of our written policies and procedures regarding proxy voting and/or information on how particular proxies were voted by contacting our Chief Compliance Officer, Dave Reichert, by phone at (877) 432-4645 or by email at compliance@echo45advisors.com. Our firm does not pay for proxy voting services with soft dollars nor does our firm charge an additional fee to vote proxies. Item 18: Financial Information Inclusion of a Balance Sheet: Our firm does not require the prepayment of more than $1,200 in fees when services cannot be rendered within 6 months. ADV Part 2A – Firm Brochure Page 28 Echo45 Advisors LLC  Disclosure of Financial Condition: Our firm does not have a financial condition or commitment that impairs our ability to meet contractual and fiduciary obligations to clients. Bankruptcy Petition: Our firm has never been the subject of a bankruptcy proceeding. ADV Part 2A – Firm Brochure Page 29 Echo45 Advisors LLC