Expressive Wealth LLC

F O R M A D V P A R T 2 A D I S C L O S U R E B R O C H U RE Expressive Wealth LLC Office Address: 6650 N Northwest Hwy Ste 1W Tel: Chicago, IL 60631 Email: 847-595-8812 lauren@expressivewealth.com expressivewealth.com March 16, 2026 This brochure provides information about the qualifications and business practices of Expressive Wealth LLC. Being registered as an investment adviser does not imply a certain level of skill or training. If you have any questions about the contents of this brochure, please contact us at 847- 595-8812. The information in this brochure has not been approved or verified by the United A D D I T I O N A L I N F O R M A T I O N A B O U T E X P R E S S I V E W E A L T H L L C ( C R D States Securities and Exchange Commission, or by any state securities authority. # 3 2 9 9 7 4 ) I S A V A I L A B L E O N T H E S E C ’ S W E B S I T E A T W W W . A D V I S E R I N F O . S E C . G O V  Item 2: Material Changes Annual Update Material Changes since the Last Update The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of the Firm Brochure. Since the last annual amendment filing on March 13, 2025, the following changes have • occurred: • Item 5 was updated for insurance-related compensation Full Brochure Available Item 10 was updated to reflect insurance-related conflicts This Firm Brochure being delivered is the complete brochure for the Firm.  Item 3: Table of Contents Form ADV – Part 2A – Firm Brochure Item 1: Cover Page Item 2: Material Changes .................................................................................................................... ii Annual Update ................................................................................................................................................................... ii Material Changes since the Last Update.................................................................................................................. ii Item 3: Table of Contents ................................................................................................................... iii Full Brochure Available .................................................................................................................................................. ii Item 4: Advisory Business .................................................................................................................. 1 Firm Description ............................................................................................................................................................... 1 Types of Advisory Services ........................................................................................................................................... 1 Client Tailored Services and Client Imposed Restrictions ............................................................................... 3 Wrap Fee Programs ......................................................................................................................................................... 3 Item 5: Fees and Compensation ....................................................................................................... 4 Client Assets under Management .............................................................................................................................. 4 Method of Compensation and Fee Schedule .......................................................................................................... 4 Client Payment of Fees ................................................................................................................................................... 6 Additional Client Fees Charged ................................................................................................................................... 6 Prepayment of Client Fees ............................................................................................................................................ 6 Item 6: Performance-Based Fees and Side-by-Side Management ........................................ 7 External Compensation for the Sale of Securities to Clients ........................................................................... 7 Item 7: Types of Clients ....................................................................................................................... 7 Sharing of Capital Gains ................................................................................................................................................. 7 Description .......................................................................................................................................................................... 7 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................ 7 Account Minimums .......................................................................................................................................................... 7 Methods of Analysis ......................................................................................................................................................... 7 Investment Strategy ........................................................................................................................................................ 8 Item 9: Disciplinary Information ................................................................................................... 10 Security Specific Material Risks .................................................................................................................................. 8 Criminal or Civil Actions ............................................................................................................................................. 10 Administrative Enforcement Proceedings .......................................................................................................... 10  Item 10: Other Financial Industry Activities and Affiliations ............................................. 10 Self- Regulatory Organization Enforcement Proceedings ............................................................................ 10 Broker-Dealer or Representative Registration ................................................................................................. 10 Futures or Commodity Registration ...................................................................................................................... 10 Material Relationships Maintained by this Advisory Business and Conflicts of Interest ................ 11 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Recommendations or Selections of Other Investment Advisors and Conflicts of Interest ............. 11 Trading ................................................................................................................................................... 11 Code of Ethics Description ......................................................................................................................................... 11 Investment Recommendations Involving a Material Financial Interest and Conflict of Interest. 12 Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest 12 Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Item 12: Brokerage Practices ......................................................................................................... 12 Transactions and Conflicts of Interest .................................................................................................................. 12 Factors Used to Select Broker-Dealers for Client Transactions ................................................................. 12 Item 13: Review of Accounts ........................................................................................................... 14 Aggregating Securities Transactions for Client Accounts ............................................................................. 13 Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved ............................................................................................................................................................................. 14 Review of Client Accounts on Non-Periodic Basis ........................................................................................... 14 Item 14: Client Referrals and Other Compensation ................................................................ 14 Content of Client Provided Reports and Frequency ........................................................................................ 14 Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest ............................................................................................................................................................................... 14 Item 15: Custody .................................................................................................................................. 15 Advisory Firm Payments for Client Referrals .................................................................................................... 14 Item 16: Investment Discretion ..................................................................................................... 15 Account Statements ...................................................................................................................................................... 15 Item 17: Voting Client Securities ................................................................................................... 15 Discretionary Authority for Trading...................................................................................................................... 15 Item 18: Financial Information ...................................................................................................... 15 Proxy Votes ...................................................................................................................................................................... 15 Balance Sheet .................................................................................................................................................................. 15  Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients ............................................................................................................................................................................ 15 Bankruptcy Petitions during the Past Ten Years .............................................................................................. 16  Item 4: Advisory Business Firm Description Types of Advisory Services Expressive Wealth LLC (“EX”) was founded and became registered as an investment advisor in 2024. Lauren Genuardi is 50% owner and Managing Partner. Vanessa Martinez is 50% owner and Managing Partner. ASSET MANAGEMENT EX offers discretionary asset management services to advisory Clients. EX will offer Clients ongoing asset management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation which include alternative investments, portfolio monitoring and the overall investment program will be based on the above factors. The Client will authorize EX discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. When deemed appropriate for the Client, EX may hire Sub-Advisors to manage all or a portion of the assets in the Client account. EX has full discretion to hire and fire Sub-Advisors as they deem suitable. Sub-Advisors will maintain the models or investment strategies agreed upon between Sub-Advisor and EX. Sub-Advisors execute trades on behalf of EX in Client accounts. EX will be responsible for the overall direct relationship with the Client. EX Client-Directed Accounts retains the authority to terminate the Sub-Advisor relationship at EX’s discretion. EX will assist in the opening, closing and transferring of accounts. EX will not have discretion at any time on these accounts. Client is solely responsible for the assets held within the accounts and their values which could increase or decrease (potential loss of principal). EX will only execute trades in the account upon Client request. EX can furnish 3rd party analysis reports per the client’s request. ASSETS HELD AWAY EX uses a third party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, EX will review the current account allocations. When deemed necessary, EX will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. - 1 -  ASSETS UNDER ADVISEMENT EX will work with individuals on determining their individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, and asset allocation are based on the above factors. The accounts will be monitored on a quarterly basis. EX will provide recommendations to the client on a quarterly basis, but implementation will be at the sole discretion of the client. ERISA PLAN SERVICES EX provides service to qualified retirement plans including 401(k) plans, 403(b) plans, pension and profit-sharing plans, cash balance plans, and deferred compensation plans. EX ERISA 3(38) Investment Manager. will act as a 3(38) advisor. EX can also act as an ERISA 3(38) Investment Manager in which it has discretionary management and control of a given retirement plan’s assets. EX would then become solely responsible and liable for the selection, monitoring and replacement of the plan’s investment options. 1. • Fiduciary Services are: • EX has discretionary authority and will make the final decision regarding the initial selection, retention, removal and addition of investment options in accordance with the Plan’s investment policies and objectives. • Assist the Client with the selection of a broad range of investment options consistent with ERISA Section 404(c) and the regulations thereunder. • Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan. Provide discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment option for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5). 2. • Non-fiduciary Services are: • Assist in the education of Plan participants about general investment information and the investment options available to them under the Plan. Client understands the EX’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, the EX is not providing fiduciary advice as defined by ERISA to the Plan participants. EX will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan. Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. - 2 -  EX may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between EX and Client. 3. EX has no responsibility to provide services related to the following types of assets • (“Excluded Assets”): • • • • • • not Employer securities; Real estate (except for real estate funds or publicly traded REITs); Stock brokerage accounts or mutual fund windows; Participant loans; Non-publicly traded partnership interests; Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or Other hard-to-value or illiquid securities or property. Excluded Assets will be included in calculation of Fees paid to the Adviser on the ERISA Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. FINANCIAL PLANNING AND CONSULTING EX may offer broad-based, modular, and consultative financial planning services. Financial planning will 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 our firm for financial planning services, we will meet with you to gather information about your financial circumstances 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 our firm. 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. EX suggests the client work closely with his/her attorney, accountant or insurance agency. To the extent requested by you, we may recommend the services of other professionals. If you engage any recommended professionals and a dispute arises thereafter relative to such engagement, you agree to seek recourse exclusively from and against the engaged professional. Client Tailored Services and Client Imposed Restrictions Wrap Fee Programs The goals and objectives for each Client are documented in our Client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without written Client consent. EX does not sponsor any wrap fee programs. - 3 -  Client Assets under Management Discretionary Amounts: Non-discretionary Amounts: $165,160,124 $11,079 Date Calculated: December 31, 2025 Item 5: Fees and Compensation Method of Compensation and Fee Schedule Assets Under Management Annual Fee ASSET MANAGEMENT EX charges an annual investment advisory fee based on the total assets under management as follows: First $2,500,000 ($0 - $2,500,000) Next $2,500,000 ($2,500,001 - $5,000,000) Next $5,000,000 ($5,000,001 - $10,000,000) Amount Over $10,000,000 1.00% 0.90% 0.80% 0.70% This is a tiered/blended fee schedule, the asset management fee is calculated by applying different rates to different portions of the portfolio. The annual fee is negotiable. Fees are billed monthly in arrears based on the amount of assets managed as of the close of business on the last business day of the previous month. Lower fees for comparable services may be available from other sources. Clients may terminate their account within five (5) business days of signing the Investment Advisory Agreement with no obligation and without penalty. After the initial five (5) business days, the agreement may be terminated by EX with thirty (30) days written notice to Client and by the Client at any time with written notice to EX. For accounts opened or closed mid-billing period, fees will be prorated based on the days services are provided during the given period. All unpaid earned fees will be due to EX. Client shall be given thirty (30) days prior written notice of any increase in fees. Any increase in fees will be acknowledged in writing by both parties before any increase in said fees occurs. EX may utilize the services of a Sub-Advisor to manage Clients’ investment portfolios. EX will enter into Sub-Advisor agreements with other registered investment advisor firms. When using Sub-Advisors, the Client will not pay additional fees. The Sub-Advisors fees are Prior fee schedules may be in effect. Legacy clients (those whose account engagements with the inclusive of the total fee disclosed by EX. firm were in effect before the above stated fee schedule) may be subject to fee structures no longer offered to new clients. The exact fee for services will be agreed upon and disclosed in the client agreement prior to services being provided. Client-Directed Accounts EX does not charge a fee on these accounts. ERISA PLAN SERVICES - 4 -  The annual fees are based on the market value of the Included Assets and will not exceed 1%. The annual fee is negotiable and may be charged as a percentage of the Included Assets or as a flat fee. Fees may be charged quarterly or monthly in arrears or in advance based on the assets as calculated by the custodian or record keeper of the Included Assets (without adjustments for anticipated withdrawals by Plan participants or other anticipated or scheduled transfers or distribution of assets). If the services to be provided start any time other than the first day of a quarter or month, the fee will be prorated based on the number of days remaining in the quarter or month. If this Agreement is terminated prior to the end of the billing cycle, EX shall be entitled to a prorated fee based on the number of days during the fee period services were provided or Client will be due a prorated refund of fees for days services were not provided in the billing cycle. The fee schedule, which includes compensation of EX for the services is described in detail in Schedule A of the ERISA Plan Agreement. The Plan is obligated to pay the fees, however the Plan Sponsor may elect to pay the fees. Client may elect to be billed directly or have fees deducted from Plan Assets. EX does not reasonably expect to receive any additional compensation, directly or indirectly, for its services under this Agreement. If additional compensation is received, EX will disclose this compensation, the services rendered, and the payer of compensation. EX will offset the compensation against the fees agreed upon under the Agreement. ASSET HELD AWAY EX offers discretionary direct asset management services to advisory Clients. EX charges an annual investment advisory fee not to exceed 1.00% of the assets managed. The annual fee is negotiable. Fees are billed monthly in arrears based on the amount of assets managed as of the close of business on the last business day of the previous month. Lower fees for comparable services may be available from other sources. Clients may terminate their account within five (5) business days of signing the Investment Advisory Agreement with no obligation and without penalty. After the initial five (5) business days, the agreement may be terminated by EX with thirty (30) days written notice to Client and by the Client at any time with written notice to EX. For accounts opened or closed mid-billing period, fees will be prorated based on the days services are provided during the given period. All unpaid earned fees will be due to EX. Client shall be given thirty (30) days prior written notice of any increase in fees. Any increase in fees will be acknowledged in writing by both parties before any increase in said fees occurs. No fee adjustment will be made for Account deposits and withdrawals during a billing period. In addition to the fees paid to EX, investments used in managing the Account may subject Client to additional fees. For example, mutual funds, index funds, exchange traded funds and private funds typically charge ongoing management fees and have other expenses for the operation of those funds. These fees should not be confused with “loads” or commissions. EX does not receive any additional compensation, either directly or indirectly, from these investments. ASSETS UNDER ADVISEMENT - 5 -  Fees for these services will be based on a percentage of Assets Under Management. The annual fee will be .25%. Fees will be paid in arrears every month. Client will be provided an invoice at the commencement of services payable within ten (10) days of receipt. Clients may choose to pay EX directly or have the amount deducted from another account managed by EX. Clients may terminate their account within five (5) business days of signing the Investment Advisory Agreement with no obligation and without penalty. If the Client cancels after five (5) business days, any unearned fees will be refunded to the Client, or any unpaid earned fees will be due to EX. FINANCIAL PLANNING AND CONSULTING EX charges either a fixed fee or hourly fee for financial planning and consulting services. Prior to the planning process the Client will be provided an estimated plan fee. Services are completed and delivered inside of ninety (90) days contingent on the timely receipt of all applicable documents from the Client. Client may cancel within five (5) days of signing Agreement with no obligation. If the Client cancels after five (5) business days, any unearned fees will be refunded to the Client, or any unpaid earned fees will be due to EX based on the hours of work expended by EX. Fees for financial planning and consulting services are due 100% in advance or 50% in advance with the remainder due upon delivery of the completed plan or consultation. EX reserves the right to waive the fee should the Client have $1,000,000 or more of assets under management with EX. FIXED FEES Financial planning services are offered based on a negotiable fixed fee that ranges from $4,000 to $10,000 dependent upon the complexity and Client needs; fee determined at EX discretion. HOURLY FEES Client Payment of Fees Consulting services are offered based on an hourly fee of $500 per hour. Fees for asset management services are deducted from a designated Client account to facilitate billing. The Client must consent in advance to direct debiting of their investment account. Fees for ERISA services will either be deducted from Plan assets or paid directly to EX. The Client must consent in advance to direct debiting of their investment account. Additional Client Fees Charged Fees for financial planning and consulting will be billed to the Client and paid directly to EX. Prepayment of Client Fees Custodians may charge transaction fees and other related costs on the purchases or sales of mutual funds, equities, bonds, options and exchange-traded funds. Mutual funds, money market funds and exchange-traded funds also charge internal management fees, which are disclosed in the fund’s prospectus. EX does not receive any compensation from these fees. All of these fees are in addition to the management fee you pay to EX. For more details on the brokerage practices, see Item 12 of this brochure. A portion of the fees for financial planning are billed in advance. - 6 -  Fees for ERISA 3(38) services may be billed in advance. External Compensation for the Sale of Securities to Clients If the Client cancels after five (5) business days, any unearned fees will be refunded to the Client, or any unpaid earned fees will be due to EX. Investment Advisor Representatives of EX may receive external compensation from sales of investment related products such as insurance as licensed insurance agents. This represents a conflict of interest because it gives an incentive to recommend products based on the commission received. This conflict is mitigated by disclosures, procedures and EX’s fiduciary obligation to place the best interest of the Client first and Clients are not required to purchase any products or services. Clients have the option to purchase these products through another insurance agent of their choosing. No insurance-related compensation is passed on to the EX, nor are referrals provided to the firm’s Investment Advisor Representatives who may receive insurance-related compensation. Item 6: Performance-Based Fees and Side-by-Side Management Sharing of Capital Gains Fees are not based on a share of the capital gains or capital appreciation of managed securities. Item 7: Types of Clients Description Account Minimums EX generally provides investment advice to individuals, high net worth individuals, trusts or estates. Client relationships vary in scope and length of service. EX requires a $250,000 minimum to open an account; accounts may be opened at a lesser amount upon EX’s discretion. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include fundamental analysis, technical analysis and cyclical analysis. Investing in securities involves risk of loss that Clients should be prepared to bear. Past performance is not a guarantee of future returns. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not take into account new patterns that emerge over time. - 7 -  Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are twofold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. Investment Strategy Analysis of Sub-Advisor strategies includes an examination of the experience, investment philosophies and performance of the investment managers to determine if the Sub-Advisor can invest over time with varying economic conditions. EX also reviews the Sub-Advisor’s underlying strategies, holdings, concentrations and leverage as part of their overall risk assessment. Investing in securities involves risk of loss that Clients should be prepared to bear. Past performance is not a guarantee of future returns. Security Specific Material Risks The investment strategy for a specific Client is based upon the objectives stated by the Client during consultations. The Client may change these objectives at any time by providing written notice to EX. Each Client executes a Client profile form or similar form that documents their objectives and their desired investment strategy. All investment programs have certain risks that are borne by the investor. Our investment approach constantly keeps the risk of loss in mind. Investors face the following investment • Market Risk risks and should discuss these risks with EX: • : The prices of securities in which Clients invest may decline in response to certain events taking place around the world, including those directly involving the companies whose securities are owned by a fund; conditions affecting the general economy; overall market changes; local, regional or global political, social or economic instability; and currency, interest rate and commodity price fluctuations. Investors should have a long-term perspective and be able to tolerate potentially sharp declines in Interest-rate Risk market value. • : Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, Inflation Risk causing their market values to decline. : When any type of inflation is present, a dollar today will buy more than a • Currency Risk dollar next year, because purchasing power is eroding at the rate of inflation. • Reinvestment Risk : Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Management Risk: : This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. The advisor’s investment approach may fail to produce the intended results. If the advisor’s assumptions regarding the performance of a specific asset class or fund are not realized in the expected time frame, the overall performance of the Client’s portfolio may suffer. - 8 -  • Equity Risk: • Fixed Income Risk: Equity securities tend to be more volatile than other investment choices. The value of an individual mutual fund or ETF can be more volatile than the market as a whole. This volatility affects the value of the Client’s overall portfolio. Small- and mid-cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product lines, financial resources, and less management experience than larger companies. Smaller companies may also have a lower trading volume, which may disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. • The issuer of a fixed income security may not be able to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower rating, the value of the debt security will decline because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities held by a fund is likely to decrease. A nominal interest rate is the sum of a real Investment Companies Risk: interest rate and an expected inflation rate. • Foreign Securities Risk: When a Client invests in open end mutual funds or ETFs, the Client indirectly bears their proportionate share of any fees and expenses payable directly by those funds. Therefore, the Client will incur higher expenses, which may be duplicative. In addition, the Client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value or (ii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. Adviser has no control over the risks taken by the underlying funds in which Client invests. • Long-term trading Funds in which Clients invest may invest in foreign securities. Foreign securities are subject to additional risks not typically associated with investments in domestic securities. These risks may include, among others, currency risk, country risks (political, diplomatic, regional conflicts, terrorism, war, social and economic instability, currency devaluations and policies that have the effect of limiting or restricting foreign investment or the movement of assets), different trading practices, less government supervision, less publicly available information, limited trading markets and greater volatility. To the extent that underlying funds invest in issuers located in emerging markets, the risk may be heightened by political changes, changes in taxation, or currency controls that could adversely affect the values of these investments. Emerging markets have been more volatile than the markets of developed countries with more mature economies. is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose Clients to various other types of risk that will typically surface at various intervals during the time the Client owns the - 9 -  • Short-term trading investments. These risks include but are not limited to inflation (purchasing power) risk, . interest rate risk, economic risk, market risk, and political/regulatory risk. • Options Trading risks include liquidity, economic stability and inflation : The risks involved with trading options are that they are very time sensitive investments. An options contract is generally a few months. Clients should be aware that the use of options involves additional risks. The risks of covered call writing include the potential for the market to rise sharply. In such case, the security may be called away and the account will no longer hold the security. When purchasing options there is the risk that the entire premium paid for the option can be lost if the option is not exercised or otherwise sold prior to the option’s expiration date. When selling (“writing”) options, the risk of loss can be much greater if the options are written uncovered (“naked”). The risk of loss can far exceed the amount of the premium received for an uncovered option and in the case of an uncovered call option the potential loss is unlimited. • The risks associated with utilizing Sub-Advisors include: o Manager Risk • Sub-Advisor fails to execute the stated investment strategy o Business Risk • Sub-Advisor has financial or regulatory problems The specific risks associated with the portfolios of the Sub-Advisor are disclosed in the Form ADV Part 2 of the Sub-Advisor. Item 9: Disciplinary Information Criminal or Civil Actions Administrative Enforcement Proceedings EX and its management have not been involved in any criminal or civil action. Self- Regulatory Organization Enforcement Proceedings EX and its management have not been involved in administrative enforcement proceedings. EX and its management have not been involved in any self-regulatory organizational enforcement proceedings that are material to a Client’s or prospective Client’s evaluation of EX or the integrity of its management. Item 10: Other Financial Industry Activities and Affiliations Broker-Dealer or Representative Registration EX is not registered as a broker-dealer, and no affiliated representatives of EX are registered Futures or Commodity Registration representatives of a broker-dealer. Neither EX nor its affiliated representatives are registered or have an application pending to register as a futures commission merchant, commodity pool operator, or a commodity trading advisor. - 10 -  Material Relationships Maintained by this Advisory Business and Conflicts of Interest EX representatives may be licensed insurance agents that offer insurance products and receive separate compensation. These practices represent a conflict of interest because it gives an incentive to recommend products based on the commission amount received. This conflict is mitigated by disclosures, procedures and EX’s fiduciary obligation to place the best interest of the Client first and the Clients are not required to purchase any products. Clients have the option to purchase these Recommendations or Selections of Other Investment Advisors and Conflicts of Interest products through another insurance agent of their choosing. EX may also utilize the services of a Sub-Advisor to manage Clients’ investment portfolios. Sub-Advisors will maintain the models or investment strategies agreed upon between Sub- Advisor and EX. Sub-Advisors execute all trades on behalf of EX in Client accounts. EX will be responsible for the overall direct relationship with the Client. EX retains the authority to terminate the Sub-Advisor relationship at EX’s discretion. Each Sub-Advisor utilized by EX charges different asset management fees for the portfolios that they manage. In some cases the management fee for one Sub-Advisor may be lower than for another Sub-Advisor. This causes a conflict of interest because choosing a Sub-Advisor with a lower fee means that EX will retain more of the fee for themselves. This practice represents a conflict of interest as EX may select Sub-Advisors who charge a lower fee for their services than other Sub-Advisors. This conflict is mitigated by disclosures, procedures and by the fact that EX has a fiduciary duty to place the best interest of the Client first when selecting Sub-Advisors. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Description include employees and/or The affiliated persons (affiliated persons independent contractors) of EX have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected of EX affiliated persons and addresses conflicts that may arise. The Code defines acceptable behavior for affiliated persons of EX. The Code reflects EX and its supervised persons’ responsibility to act in the best interest of their Client. One area which the Code addresses is when affiliated persons buy or sell securities for their personal accounts and how to mitigate any conflict of interest with our Clients. We do not allow any affiliated persons to use non-public material information for their personal profit or to use internal research for their personal benefit in conflict with the benefit to our Clients. EX’s policy prohibits any person from acting upon or otherwise misusing non-public or inside information. No advisory representative or other affiliated person, officer or director of EX may recommend any transaction in a security or its derivative to advisory Clients or engage in personal securities transactions for a security or its derivatives if the advisory representative possesses material, non-public information regarding the security. EX’s Code is based on the guiding principle that the interests of the Client are our top priority. EX’s officers, directors, advisors, and other affiliated persons have a fiduciary duty to our - 11 -  Clients and must diligently perform that duty to maintain the complete trust and confidence of our Clients. When a conflict arises, it is our obligation to put the Client’s interests over the interests of either affiliated persons or the company. The Code applies to “access” persons. “Access” persons are affiliated persons who have access to non-public information regarding any Clients' purchase or sale of securities, or non-public information regarding the portfolio holdings of any reportable fund, who are involved in making securities recommendations to Clients, or who have access to such recommendations that are non-public. EX will provide a copy of the Code of Ethics to any Client or prospective Client upon request. Investment Recommendations Involving a Material Financial Interest and Conflict of Interest EX and its affiliated persons do not recommend to Clients securities in which we have a material financial interest. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest EX and its affiliated persons may buy or sell securities that are also held by Clients. In order to mitigate conflicts of interest such as trading ahead of Client transactions, affiliated persons are required to disclose all reportable securities transactions as well as provide EX with copies of their brokerage statements. The Chief Compliance Officer of EX is Matt Murray. He reviews all trades of the affiliated persons each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not front run or disadvantage trading for Clients. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest EX does not have a material financial interest in any securities being recommended. However, affiliated persons may buy or sell securities at the same time they buy or sell securities for Clients. In order to mitigate conflicts of interest such as front running, affiliated persons are required to disclose all reportable securities transactions as well as provide EX with copies of their brokerage statements. The Chief Compliance Officer of EX is Matt Murray. He reviews all trades of the affiliated persons each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not front run or disadvantage trading for Clients. Item 12: Brokerage Practices Factors Used to Select Broker-Dealers for Client Transactions EX will require the use of a particular broker-dealer based on their duty to seek best execution for the Client, meaning they have an obligation to obtain the most favorable terms for a Client under the circumstances. The determination of what may constitute best execution and price in the execution of a securities transaction by a broker involves a number of considerations and is subjective. Factors affecting brokerage selection include the overall direct net economic result to the portfolios, the efficiency with which the transaction is affected, the ability to affect the transaction where a large block is involved, the operational - 12 -  facilities of the broker-dealer, the value of an ongoing relationship with such broker and the financial strength and stability of the broker. EX will select appropriate brokers based on a number of factors including but not limited to their relatively low transaction fees and reporting ability. EX relies on its broker to provide its execution services at the best prices available. Lower fees for comparable services may be available from other sources. Clients pay for any and all custodial fees in addition to the advisory fee charged by EX. EX does not receive any portion of the trading fees. • Research and Other Soft Dollar Benefits EX will require the use of Charles Schwab & Co., Inc. The Securities and Exchange Commission defines soft dollar practices as arrangement under which products or services other than execution services are obtained by EX from or through a broker-dealer in exchange for directing Client transactions to the broker-dealer. Although EX has no formal soft dollar arrangements, EX may receive products, research and/or other services from custodians or broker-dealers connected to Client transactions or “soft dollar benefits”. As permitted by Section 28(e) of the Securities Exchange Act of 1934, EX receives economic benefits as a result of commissions generated from securities transactions by the custodian or broker-dealer from the accounts of EX. EX cannot ensure that a particular Client will benefit from soft dollars or the Client’s transactions paid for the soft dollar benefits. EX does not seek to proportionately allocate benefits to Client accounts to any soft dollar benefits generated by the accounts. • Brokerage for Client Referrals A conflict of interest exists when EX receives soft dollars which could result in higher commissions charged to Clients. This conflict is mitigated by the fact that EX has a fiduciary responsibility to act in the best interest of its Clients and the services received are beneficial to all Clients. EX does not receive Client referrals from any custodian in exchange for using that • Directed Brokerage broker-dealer. Aggregating Securities Transactions for Client Accounts EX does not allow Client directed brokerage accounts. EX is authorized in its discretion to aggregate purchases and sales and other transactions made for the account with purchases and sales and transactions in the same securities for other Clients of EX. All Clients participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rated basis. If aggregation is not allowed or infeasible and individual transactions occur (e.g., withdrawal or liquidation requests, odd-lot trades, etc.) an account may potentially be assessed higher costs or less favorable prices than those where aggregation has occurred. - 13 -  Item 13: Review of Accounts Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved Account reviews are performed quarterly by an Investment Advisor Representative of EX. Account reviews are performed more frequently when market conditions dictate. Reviews of Client accounts include, but are not limited to, a review of Client documented risk tolerance, adherence to account objectives, investment time horizon, suitability criteria and reviewing target allocations of each asset class to identify if there is an opportunity for rebalancing. Review of Client Accounts on Non-Periodic Basis Financial plans and consultations are updated as requested by the Client and pursuant to a new or amended agreement. Content of Client Provided Reports and Frequency Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws, new investment information, and changes in a Client's own situation. Clients receive written account statements no less than quarterly for managed accounts. Account statements are issued by the Client’s custodian. Client receives confirmations of each transaction in account from custodian and an additional statement during any month in which a transaction occurs. Item 14: Client Referrals and Other Compensation Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest Advisory Firm Payments for Client Referrals EX does not receive any economic benefits from external sources. EX may enter into agreements with individuals and organizations, which may be affiliated or unaffiliated with EX, that refer Clients to EX in exchange for compensation. All such agreements will be in writing and comply with the requirements of Federal or State regulation. If a Client is introduced to EX by a referring party, EX may pay that referring party a fee. While the specific terms of each agreement may differ, generally, the compensation will be based upon EX’s engagement of new Clients and is calculated using a varying percentage of the fees paid to EX by such Clients. Any such fee shall be paid solely from EX’s investment management fee, and shall not result in any additional charge to the Client. Each prospective Client who is referred to EX under such an arrangement will receive a copy of this brochure and a separate written disclosure document disclosing the nature of the relationship between the referring party and EX and the amount of compensation that will be paid by EX to the referring party. The referring party is required to obtain the Client’s signature acknowledging receipt of EX’s disclosure brochure and the written disclosure statement. - 14 -  Item 15: Custody Account Statements All assets are held at qualified custodians, which means the custodians provide account statements directly to Clients at their address of record at least monthly. Clients are urged to carefully compare the account statements received directly from their custodians to any documentation or reports prepared by EX. EX is deemed to have limited custody solely because advisory fees are directly deducted from Client’s accounts by the custodian on behalf of EX. Item 16: Investment Discretion Discretionary Authority for Trading EX accepts discretionary authority to manage securities accounts on behalf of Clients. EX has the authority to determine, without obtaining specific Client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. Client will authorize EX discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. If consent for discretion is not given by client, EX will manage on a non-discretionary basis and will obtain Clients requests for executing each transaction. EX allows Clients to place certain restrictions, as outlined in the Client’s Investment Policy Statement or similar document. These restrictions must be provided to EX in writing. The Client approves the custodian to be used and the commission rates paid to the custodian. EX does not receive any portion of the transaction fees or commissions paid by the Client to the custodian. Item 17: Voting Client Securities Proxy Votes EX does not vote proxies on securities. Clients are expected to vote their own proxies. The Client will receive their proxies directly from the custodian of their account or from a transfer agent. When assistance on voting proxies is requested, EX will provide recommendations to the Client. If a conflict of interest exists, it will be disclosed to the Client. If the Client requires assistance or has questions, they can reach out to the investment advisor representatives of the firm at the contact information on the cover page of this document. Item 18: Financial Information Balance Sheet A balance sheet is not required to be provided to Clients because EX does not serve as a custodian for Client funds or securities and EX does not require prepayment of fees of more than $1200 per Client and six months or more in advance. Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients EX has no condition that is reasonably likely to impair our ability to meet contractual commitments to our Clients. - 15 -  Bankruptcy Petitions during the Past Ten Years EX has not had any bankruptcy petitions in the last ten years. - 16 -