FC WEALTH SOLUTIONS LLC

FC Wealth Solutions LLC Firm Brochure Form ADV Part 2A – This brochure provides information about the qualifications and business practices of FC Wealth Solutions LLC. If you have any questions about the contents of this brochure, please contact us at (614) 212-1015 or by email at: info@fcwealthsolutions.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. - Additional information about FC Wealth Solutions LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. FC Wealth Solutions LLC’s CRD number is: . 286381 579 Executive Campus Drive Suite 230 Westerville, OH 43082 (614) 212-1015 info@fcwealthsolutions.com https://fcwealthsolutions.com Registration does not imply a certain level of skill or training. Version Date: 03/31/2026 i  Item 2: Material Changes Since our last annual update, the following material changes have occurred: Billing Practices The Firm has updated its billing practices to provide that advisory fees are now assessed monthly in arrears, rather than on a quarterly basis. While the Firm’s annualized advisory fee schedule has not changed, this update affects the timing and frequency of fee assessments. Clients will now incur fees monthly, based on account values during the applicable billing period, with adjustments for contributions and withdrawals. Additional information regarding the Firm’s advisory fees is provided in Item 5 (Fees and Compensation). Principal Office Address The Firm has updated its principal office address. ii  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ................................................................................................................................................................................................................................... ii Item 3: Table of Contents ................................................................................................................................................................................................................................. iii Item 4: Advisory Business ................................................................................................................................................................................................................................ 5 A. Description of the Advisory Firm ........................................................................................................................................................................................................ 5 B. Types of Advisory Services ................................................................................................................................................................................................................... 5 C. Client Tailored Services and Client Imposed Restrictions.......................................................................................................................................................... 6 D. Wrap Fee Programs ................................................................................................................................................................................................................................. 6 E. Assets Under Management .....................................................................................................................................................................................................................6 Item 5: Fees and Compensation ..................................................................................................................................................................................................................... 7 A. Fee Schedule ................................................................................................................................................................................................................................................ 7 B. Payment of Fees.......................................................................................................................................................................................................................................... 7 C. Client Responsibility For Third Party Fees ..................................................................................................................................................................................... 8 D. Prepayment of Fees .................................................................................................................................................................................................................................. 8 E. Outside Compensation For the Sale of Securities to Clients.................................................................................................................................................. 8 Item 6: Performance-Based Fees and Side-By-Side Management .................................................................................................................................................... 8 Item 7: Types of Clients ..................................................................................................................................................................................................................................... 8 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ................................................................................................................................................ 9 A. Methods of Analysis and Investment Strategies ................................................................................................................................................................ 9 B. Material Risks Involved ............................................................................................................................................................................................................. 10 C. Risks of Specific Securities Utilized ...................................................................................................................................................................................... 11 Item 9: Disciplinary Information .................................................................................................................................................................................................................. 14 A. Criminal or Civil Actions .......................................................................................................................................................................................................... 14 B. Administrative Proceedings ..................................................................................................................................................................................................... 14 C. Self-regulatory Organization (SRO) Proceedings ............................................................................................................................................................ 14 Item 10: Other Financial Industry Activities and Affiliations ........................................................................................................................................................ 14 A. Registration as a Broker/Dealer or Broker/Dealer Representative ........................................................................................................................ 14 B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor ..................................14 C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests ........................................................... 14 D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections ............................................ 15 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ....................................................................................... 15 A. Code of Ethics ................................................................................................................................................................................................................................ 15 B. Recommendations Involving Material Financial Interests ........................................................................................................................................... 15 C. Investing Personal Money in the Same Securities as Clients ...................................................................................................................................... 15 D. Trading Securities At/Around the Same Time as Clients’ Securities ...................................................................................................................... 15 Item 12: Brokerage Practices ........................................................................................................................................................................................................................ 16 iii  A. Factors Used to Select Custodians and/or Broker/Dealers ......................................................................................................................................... 16 1. Research and Other Soft-Dollar Benefits ...................................................................................................................................................................... 16 2. Brokerage for Client Referrals ........................................................................................................................................................................................... 16 3. Clients Directing Which Broker/Dealer/Custodian to Use ................................................................................................................................. 16 B. Aggregating (Block) Trading for Multiple Client Accounts ...................................................................................................................................... 17 Item 13: Review of Accounts ......................................................................................................................................................................................................................... 17 A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews ..................................................................................................... 17 B. Factors That Will Trigger a Non-Periodic Review of Client Accounts ................................................................................................................ 17 C. Content and Frequency of Regular Reports Provided to Clients .............................................................................................................................. 18 Item 14: Client Referrals and Other Compensation .............................................................................................................................................................................. 18 A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) ..............18 B. Compensation to Non – Advisory Personnel for Client Referrals .......................................................................................................................... 18 Item 15: Custody ................................................................................................................................................................................................................................................ 18 Item 16: Investment Discretion .................................................................................................................................................................................................................... 18 Item 17: Voting Client Securities (Proxy Voting)................................................................................................................................................................................... 19 Item 18: Financial Information ..................................................................................................................................................................................................................... 19 A. Balance Sheet ................................................................................................................................................................................................................................. 19 B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients ......................................... 19 C. Bankruptcy Petitions in Previous Ten Years .................................................................................................................................................................... 19 Item 19: Requirements For State Registered Advisers ....................................................................................................................................................................... 19 A. Principal Executive Officers and Management Persons; Their Formal Education and Business Background................................... 19 B. Other Businesses in Which This Advisory Firm or its Personnel are Engaged and Time Spent on Those (If Any) ................................ 20 C. Calculation of Performance-Based Fees and Degree of Risk to Clients ................................................................................................................... 20 D. Material Disciplinary Disclosures for Management Persons of this Firm ........................................................................................................ 20 E. Material Relationships That Management Persons Have With Issuers of Securities (If Any). ..................................................................... 20 iv  Item 4: Advisory Business A. Description of the Advisory Firm FC Wealth Solutions LLC (hereinafter FCWS) is a Limited Liability Company organized in the State of Ohio. The firm was formed in October 2016, became licensed as an investment adviser in 2017, and the principal owners are Craig Robert Cavicchia and Michael Wayne Fickell. B. Types of Advisory Services Portfolio Management Services ’ ’ FCWS offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. FCWS creates an Investment s current situation (income, tax Policy Statement for each client, which outlines the client levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Item 8 of this brochure provides additional detail about FCWS s specific investment strategies and the types of securities involved. Portfolio management services include, but are not limited to, thefollowing: • • • Investment strategy • • Asset allocation • Risktolerance Personal investment policy Asset selection Regular portfolio monitoring FCWS evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. FCWS will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Risk Profile Questionnaire, which is completed for each client. ’ ’ ’ FCWS seeks to provide that investment decisions are made in accordance with the s economic, fiduciary duties owed to its accounts and without consideration of FCWS investment or other financial interests. To meet its fiduciary obligations, FCWS attempts to avoid, among other things, investment or trading practices that systematically s policy is to advantage or disadvantage certain client portfolios, and accordingly, FCWS seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is FCWS s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. 5  Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Services Limited to Specific Types of Investments in the gold and precious metal sectors), treasury FCWS generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), equities, hedge funds, private equity funds, ETFs (including ETFs inflation protected/inflation linked bonds, commodities, non-U.S. securities and private placements. FCWS may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions ’ FCWS will tailor a program for each individual client. This will include an interview session to get to know the client s specific needs and requirements as well as a plan that will be executed by FCWS on behalf of the client. FCWS may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent FCWS from properly servicing the client account, or if the restrictions would require FCWS to deviate from its standard suite of services, FCWS reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. FCWS does not participate in any wrap fee programs. E. Assets Under Management FCWS has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $101,000,000 $0.00 12/31/2025 6  Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees Total Assets Under Management Annual Fees $0 - $2,000,000 Up to 1.50% $2,000,001 - $5,000,000 Up to 1.00% Up to 0.85% $5,000,001 – And Up The advisory fee is calculated using the value of the assets on the last business day of the prior billing period. These fees are generally negotiable, and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract. Clients may terminate the agreement without penalty for a full refund of FCWS's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract immediately upon written notice. Financial Planning Fees Fixed Fees ’ The negotiated fixed rate for creating client financial plans is between $1,000 and $5,000. Clients may terminate the agreement without penalty, for full refund of FCWS s fees, within five business days of signing the Financial Planning Agreement. Thereafter, clients may terminate the Financial Planning Agreement generally upon written notice. B. Payment of Fees Payment of Portfolio Management Fees The Firm charges advisory fees based on a percentage of assets under management (“AUM”). Fees are stated as an annualized rate and are billed monthly in arrears. Fees are calculated as follows: The applicable annual fee rate is applied to the client’s account value and accrues daily based on the daily account value. Accrued fees are summed over the billing period and assessed at the end of each month. Contributions and withdrawals during the billing period are reflected in the daily account value and are therefore prorated based on the number of days the assets are in the account. Because fees are billed in arrears on a monthly basis, clients will experience a change in the timing and frequency of fee deductions compared to the Firm’s prior quarterly billing practices. 7  Depending on account activity, the total fees paid over time may differ slightly from those that would have been charged under quarterly billing. Clients generally authorize the Firm to deduct advisory fees directly from their custodial accounts. Clients will receive account statements from the qualified custodian reflecting all fee deductions. Fixed financial planning fees are paid in arrears upon completion. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by FCWS. Please see Item 12 of this brochure regarding broker-dealer/custodian. D. Prepayment of Fees ’ FCWS may collect certain fees in advance and certain fees in arrears, as indicated above. Refunds for fees paid in advance will be returned within fourteen days to the client via check, or return deposit back into the client s account. Neither FCWS nor its supervised persons accept any compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management FCWS does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7: Types of Clients FCWS generally provides advisory services to the following types of clients: ❖ ❖ ❖ Individuals High-Net-Worth Individuals Corporations ’ s services. There is no account minimum for any of FCWS 8  Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis ’ s methods of analysis include Fundamental analysis, Modern portfolio theory, FCWS Quantitative analysis and Technical analysis. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset. Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such as the character of management or the state of employee morale, such as the value of assets, the cost of capital, historical projections of sales, and so on. Technical analysis involves the analysis of past market data; primarily price and volume. Investment Strategies FCWS uses long term trading, short term trading, margin transactions and options trading (including covered options, uncovered options, or spreading strategies) as part of its investment approach. Specifically, FCWS uses the following distinct strategies: Tactical S&P Strategy : The Tactical S&PStrategy is a short-term, mean-reversiontrading strategy that trades in and out of the S&P 500. The strategy is opportunistic in nature, meaning it will remain in cash a majority of the time and only participate when it detects opportunity. It will typically hold positions for three to four days on average and remain in cash nearly 50% of the time. It monitors a wide range of fundamental and technical indicators with a systematic, rules-based approach that seeks to identify current trading patterns with consistent, historical patterns. Core Equity Strategy ‘ ’ : The Core Equity Strategy is an actively managed ETF strategy that trades across the equity, bond and commodity markets. It focuses on making tactical asset allocation decisions using a systematic, rules-based methodology that monitors a wide range of fundamental and technical indicators. It is often fully invested in equities but has the ability to turn to cash in order to protect against adverse market shocks. The goal of the Core Equity Strategy is to capture the long-term returns of the equity market but minimize the volatility often associated with a traditional buy & hold approach. 9  Core Bond Strategy ’ : The Core Bond Strategy is an actively managed ETF strategy that invests in various passively managed fixed-income (bond) ETF s. It is a rules-based system that monitors a wide range of fundamental and technical indicators to determine itsallocation across various fixedincomesectors. It maintains a coreposition with satellite holdings that give it the ability to overweight outperforming and/or cheap sectors of the bond market. It can also make strategic investments in cash securities in order to protect it against adverse market shocks. The goal of the Core Bond Strategy is to capture the long-term returns of the bond market but minimize the volatility often associated with a traditional buy & hold approach. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis 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. Modern portfolio theory – assumes that investors are risk averse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk- expected return profile i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Quantitative analysis Investment strategies using quantitative models may perform ’ differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors historical trends, and technical issues in the construction and implementation of the models. 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 donot always follow patterns and relying solely on this method may not take into account new patterns that emerge over time. 10  Investment Strategies FCWS's use of margin transactions and options trading generally holds greater risk, and clients should be aware that there is a material risk of loss using any of those strategies. Long term trading 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 types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Margin transactions ’ use leverage that is borrowed from a brokerage firm as collateral. When losses occur, the value of the margin account may fall below the brokerage firm s threshold thereby triggering a margin call. This may force the account holder to either allocate more funds to the account or sell assets on a shorter time frame than desired. Options transactions involve a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value, as well as the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Short term trading risks include liquidity, economic stability, and inflation, in addition to the long term trading risks listed above. Frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized FCWS's use of margin transactions and options trading generally holds greater risk of capital loss. Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are notguaranteed or insured by the FDIC or any other government agency. Mutual Funds: “ ” “ fixed income nature (lower risk) or stock equity Investing in mutual funds carries the risk of capital loss and thus you may ” lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. 11  Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): “ ” electronic shares An ETFisaninvestmentfund traded onstockexchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. Real estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Hedge funds often engage in leveraging and other speculative investment practices that may increase the risk of loss; can be highly illiquid; are not required to provide periodic pricing or valuation information to investors; May involve complex tax structures and delays in distributing important tax information; are not subject to the same regulatory requirements as mutual funds; and often charge high fees. In addition, hedge funds may invest in risky securities and engage in risky strategies. Private equity funds carry certain risks. Capital calls will be made on short notice, and the failure to meet capital calls can result in significant adverse consequences, including but not limited to a total loss of investment. 12  Private placements carry a substantial risk as they are subject to less regulation than are publicly offered securities, the market to resell these assets under applicable securities laws may be illiquid, due to restrictions, and the liquidation may be taken at a substantial discount to the underlying value or result in the entire loss of the value of such assets. Commodities are tangible assets used to manufacture and produce goods or services. Commodity prices are affected by different risk factors, such as disease, storage capacity, supply, demand, delivery constraints and weather. Because of those risk factors, even a well-diversified investment in commodities can be uncertain. Options “ ” naked are contracts to purchase a security at a given price, risking that an option may expire out of the money resulting in minimal or no value. An uncovered option is a type of options contract that is not backed by an offsetting position that would help mitigate risk. The risk for a or uncovered put is not unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option positions entail buying and selling multiple options on the same underlying security, but with different strike prices or expiration dates, which helps limit the risk of other option trading strategies. Option transactions also involve risks including but not limited to economic risk, market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate risk. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Futures contracts are agreements to buy or sell a specific amount of a commodity or a financial instrument at a particular price on a stipulated future date. Futures trading involves a high amount of leverage, with a relatively small amount of money used to establish a position in assets having a much greater value, and may involve significant losses during a very short period of time. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 13  Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither FCWS nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither FCWS nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Neither FCWS nor its representatives have any registration relationships that pose a conflict of interest to FCWS advisory business. 14  D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections FCWS does not utilize nor select third-party investment advisers. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics FCWS has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. FCWS's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests FCWS does not recommend that clients buy or sell any security in which a related person to FCWS or FCWS has a material financial interest. C. Investing Personal Money in the Same Securities as Clients ’ From time to time, representatives of FCWS may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of FCWS to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. FCWS will always document any transactions that could be construed as conflicts of interest and will never engagein s disadvantage whensimilar securities arebeing bought trading that operates to the client or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of FCWS may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of FCWS to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, FCWS will never engage in 15  ’ s disadvantage if representatives of FCWS buy or sell trading that operates to the client securities at or around the same time as clients. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers ’ “ ” s duty to seek Custodians/broker-dealers will be recommended based on FCWS best which is the obligation to seek execution of securities transactions for a client execution, on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and FCWS may also consider the market expertise and research access provided by the broker- dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in FCWS's research efforts. FCWS will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian. FCWS recommends Fidelity Brokerage Services LLC and Interactive Brokers LLC. 1. Research and Other Soft-Dollar Benefits “ ” ’ While FCWS has no formal soft dollars program in which soft dollars are used to pay for third party services, FCWS may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions ( soft dollar benefits ). FCWS may enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client s transactions paid for it, and FCWS does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. FCWS benefits by not having to produce or pay for the ’ research, products or services, and FCWS will have an incentive to recommend a broker- s dealer based on receiving research or services. Clients should be aware that FCWS acceptance of soft dollar benefits may result in higher commissions charged to the client. 2. Brokerage for Client Referrals FCWS receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use FCWS may permit clients to direct it to execute transactions through a specified broker-dealer. If a client directs brokerage, then the client will be required to 16  ’ “ ” step outs acknowledge in writing that the client s direction with respect to the use of brokers supersedes any authority granted to FCWS to select brokers; this direction may result in higher commissions, which may result in a disparity between free and directed accounts; the client may be unable to participate in block trades (unless FCWS is able to engage in ); and trades for the client and other directed accounts may be executed after trades for free accounts, which may result in less favorable prices, particularly for illiquid securities or during volatile market conditions. Not all investment advisers allow their clients to direct brokerage. B. Aggregating (Block) Trading for Multiple Client Accounts If FCWS buys or sells the same securities on behalf of more than one client, then it may (but would be under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients in order to seek more favorable prices, lower brokerage commissions, or more efficient execution. In such case, FCWS would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. FCWS would determine the appropriate number of shares and select the appropriate brokers consistent with its duty to seek best execution, except for those accounts with specific brokerage direction(if any). Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews ’ All client accounts for FCWS's advisory services provided on an ongoing basis are reviewed at least quarterly by Craig R Cavicchia, Partner / COO, with regard to clients respective investment policies and risk tolerance levels. All accounts at FCWS are assigned to this reviewer. All financial planning accounts are reviewed upon financial plan creation and plan delivery by Craig R Cavicchia, Partner / COO. Financial planning clients are provided a one-time financial plan concerning their financial situation. After the presentation of the plan, there are no further reports. Clients may request additional plans or reports for a fee. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). 17  ’ s services will generally conclude upon delivery of With respect to financial plans, FCWS the financial plan. C. Content and Frequency of Regular Reports Provided to Clients ’ Each client of FCWS's advisory services provided on an ongoing basis will receive a monthly report detailing the client s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. FCWS will also provide at least quarterly a separate written statement to the client. Each financial planning client will receive the financial plan upon completion. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) FCWS does not receive any economic benefit, directly or indirectly from any third party for advice rendered to FCWS's clients. B. Compensation to Non – Advisory Personnel for Client Referrals FCWS does not directly or indirectly compensate non-advisory personnel for client referrals. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, FCWS will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Those clients will receive quarterly account statements from the custodian and, in states that require it, will receive invoices from FCWS. Clients should carefully review those statements for accuracy and are urged to compare the account statements they received from custodian with any invoices they received from FCWS. Item 16: Investment Discretion ’ ’ FCWS provides discretionary investment advisory services to clients. The advisory contract established with each client sets forth the discretionary authority for trading. Where investment s account and makes investment discretion has been granted, FCWS generally manages the client decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. In some instances, FCWS s discretionary authority in making these 18  determinations may be limited by conditions imposed by a client (in investment guidelines or objectives, or client instructions otherwise provided to FCWS. Item 17: Voting Client Securities (Proxy Voting) FCWS will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information A. Balance Sheet FCWS neither requires nor solicits prepayment of more than $500 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients ’ s ability to meet contractual commitments to clients. Neither FCWS nor its management has any financial condition that is likely to reasonably impair FCWS C. Bankruptcy Petitions in Previous Ten Years FCWS has not been the subject of a bankruptcy petition. Item 19: Requirements For State Registered Advisers A. Principal Executive Officers and Management Persons; Their Formal Education and Business Background The education and business backgrounds of FCWS's current management persons, Craig Robert Cavicchia and Michael Wayne Fickell, can be found on the Form ADV Part 2B brochure supplements for those individuals. 19  B. Other Businesses in Which This Advisory Firm or its Personnel are Engaged and Time Spent on Those (If Any) Other business activities for each relevant individual can be found on the Form ADV Part 2B brochure supplement for each such individual. C. Calculation of Performance-Based Fees and Degree of Risk to Clients FCWS does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. D. Material Disciplinary Disclosures for Management Persons of this Firm There are no civil, self-regulatory organization, orarbitration proceedings to reportunder this section. E. Material Relationships That Management Persons Have With Issuers of Securities (If Any) See Item 10.C and 11.B. 20