FINANCIAL DESIGNS WEALTH MANAGEMENT

Part 2A of Form ADV 8000 NW 7th Street, Suite 203 Miami, FL 33126 786-388-0030 info@fdwealth.net www.financialdesignswealth.com March 26, 2026 This Form ADV Part 2A (“Brochure”) provides information about the qualifications and business practices of Financial Designs Wealth Management, LLC (“FD Wealth”) (CRD #314520). If you have any questions about the contents of this Brochure, please contact us at 786-388-0030 or via email at info@fdwealth.net. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about FD Wealth is also available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov. 1  Item 2: Material Changes This item provides a summary of the specific material changes made to this Brochure. Since our last filing on September 8, 2025, in addition to editing and formatting changes, we have made the following updates: Item 4 – We updated to reflect changes in assets under management and to disclose the Firm’s entry into an agreement with Dynamic Advisor Solutions, LLC, an unaffiliated SEC-registered investment adviser, pursuant to which the Firm provides retirement plan consulting and support services to such adviser and its clients. Item 5 – We updated our fee schedule to include retirement plans. Item 10 – We provide a discussion of actual and potential conflicts of interest regarding our relationship with Fidelity Brokerage Services, LLC, and Dynamic Advisor Solutions, LLC, and how we manage these conflicts. We will provide you with a new Brochure whenever there are material changes to the information contained in this Brochure. You may obtain a copy of our most recent Brochure at any time, without charge, by contacting us at Additionally, the most recent version of our Brochure is publicly available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov. 2  Item 3: Table of Contents Item 2: Material Changes .................................................................................................................................. 2 Item 3: Table of Contents .................................................................................................................................. 3 Item 4: Advisory Business .................................................................................................................................. 4 Item 5: Fees and Compensation ........................................................................................................................ 7 Item 6: Performance-Based Fees and Side-by-Side Management ................................................................... 10 Item 7: Types of Clients ................................................................................................................................... 10 Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss ............................................................. 10 Item 9: Disciplinary Information ..................................................................................................................... 13 Item 10: Other Financial Industry Activities and Affiliations .......................................................................... 13 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................. 15 Item 12: Brokerage Practices .......................................................................................................................... 15 Item 13: Review of Accounts ............................................................................................................................ 17 Item 14: Client Referrals and Other Compensation ......................................................................................... 17 Item 15: Custody ............................................................................................................................................. 17 Item 16: Investment Discretion ........................................................................................................................ 18 Item 17: Voting Client Securities ..................................................................................................................... 18 Item 18: Financial Information ....................................................................................................................... 18 Form ADV Part 2B Brochure Supplement(s) are provided separately to clients. 3  Item 4: Advisory Business Financial Designs Wealth Management, LLC (“FD Wealth,” the Adviser or “the Firm”) was organized on April 15, 2021, as a Florida LLC. FD Wealth is owned and controlled by Jorge Valdes and Jennifer Valdes. FD Wealth offers wealth management services to individuals, high- net-worth individuals, trusts, corporations, and retirement plan sponsors. At the start of the relationship, FD Wealth’s advisers will meet with clients to determine their financial needs and goals and design a personalized investment strategy that includes selecting third-party money managers and/or Separately Managed Accounts (“SMAs”). FD Wealth offers discretionary or non-discretionary portfolio management. Client assets will be invested in a wide range of products, including U.S. and international stocks, bonds, exchange-traded funds (“ETFs”), mutual funds, and, where appropriate, alternative investments. Clients will sign an Investment Management Agreement that sets forth the terms and conditions of the engagement, and other important disclosures. The Investment Management Agreement will be effective upon acceptance by the client, FD Wealth, and the custodian. We will provide investment management supervision only for client assets listed in the Investment Management Agreement. Selection of Other Investment Advisers /Independent Third-Party Managers FD Wealth will use one or more independent third-party managers as sub-advisers. Clients will enter into a separate written agreement with the independent third-party manager. They will receive the independent third- party manager’s Brochure, Form CRS (Client Relationship Summary), and other pertinent disclosure documents. On an ongoing basis, FD Wealth will monitor the performance of accounts managed by third- party managers. FD Wealth seeks to ensure that the third-party manager’s strategies and target allocations remain aligned with our clients’ investment objectives. Retirement Plan Consulting Services FD Wealth offers pension consulting services to employee benefit plans and their fiduciaries, based on the plan's needs and the services requested by the plan sponsor or named fiduciary. In general, these services may include existing plan review and analysis, plan-level advice on fund selection and investment options consistent with the parameters outlined in the plan documents, education services for plan participants, investment performance monitoring, and/or ongoing consulting. Retirement plan consulting services will generally be non-discretionary and advisory. The ultimate decision to act on behalf of the plan shall remain with the plan sponsor or other named fiduciary. We may also assist with participant enrollment meetings and provide investment-related educational sessions to plan participants on topics such as asset allocation, diversification, risk tolerance, and investment time horizons. Our educational sessions may also include other investment-related topics relevant to the specific plan. FD Wealth may also provide additional types of pension consulting services to plans on an individually negotiated basis. We will provide the plan fiduciaries with a written document that lists all agreed-upon services and fees. 4  Retirement Plan Consulting and Support to Other Investment Advisers FD Wealth entered into an agreement with Dynamic Advisor Solutions, LLC (“Dynamic”), an unaffiliated SEC-registered investment adviser, to provide Dynamic and its registered investment advisers with retirement plan consulting and support services on defined contribution retirement plans, including 401(k) employer-sponsored plans and 401(k) profit-sharing plans. Under this arrangement, retirement plan consulting and support services are delivered through Dynamic’s technology, reporting, and investment infrastructure. Dynamic bills plan sponsors fees for these services. Dynamic charges its financial advisors service fees for performing these services and shares a portion of such fees with FD Wealth. An investment adviser representative of FD Wealth is assigned to support Dynamic by providing: • Marketing Assistance - Supports Dynamic-affiliated advisors with plan presentations, proposals, and marketing assistance. • Plan Set up and Onboarding - Assists with plan design, due diligence, and selection guidance on third-party administrator and record keeper due diligence • Ongoing Investment Support - Maintains investment line-ups and models, coordinates quarterly investment reviews. Participates in Dynamic’s investment committee in a non-voting capacity • Client Support and Escalation - Assists with advisor inquiries, service issues, plan conversions, and serves as a liaison between the record keeper, third- party administrator, and employer • Compliance Support - Ensures documentation is maintained in accordance with Dynamic’s requirements and coordinates the submission of marketing materials to the Dynamic Compliance Department for approval. Depending on the specific engagement, Dynamic may serve as the ERISA Section 3(38) investment manager for the plan, while FD Wealth may provide non-discretionary consulting support or act as a limited ERISA Section 3(21) co-fiduciary. However, FD Wealth will not make investment decisions. This arrangement poses a conflict of interest because FD Wealth serves as both a liaison to plan sponsors and a participant in investment decision-making, while maintaining a fee-paying relationship with Dynamic and using Dynamic for customized portfolios, research, and marketing support. (See discussion in Item 10 of this Brochure). In the event of disputes, service issues, or pricing concerns, FD Wealth could have divided loyalties. FD Wealth is committed to managing these conflicts, and any conflicts that may arise through the relationship with Dynamic through transparency and disclosure, policies and procedures that require us to act in the best interests of clients and plan participants, and adherence to our fiduciary duties under the Investment Advisers Act of 1940 (“Advisers Act”) and ERISA. Additionally, FD Wealth does not receive direct or indirect compensation from service providers to offset the fees it pays Dynamic, and plan sponsors retain ultimate responsibility for selecting and monitoring all service providers, including FD Wealth and Dynamic. Plan sponsors may engage different advisers or service providers for retirement plan services, and participants may select from any investment options offered under the plan, including self- directed brokerage accounts, where available. 5  Plan participants retain the right to select from the investment options offered under the plan, and in plans that offer self-directed brokerage accounts, participants may access a broader range of investment choices. Neither plan sponsors nor participants are required to follow FD Wealth’s recommendations, and both may terminate the advisory relationship in accordance with the terms of the services agreement. Retirement Account Rollovers We offer recommendations and advice concerning employer retirement plans or other qualified retirement accounts. Our recommendations may generally include that the client consider withdrawing the assets from his/her employer's retirement plan or other qualified retirement account and rolling them over to an Individual Retirement Account (“IRA”) or another qualified investment vehicle. If a client elects to roll the assets into an IRA subject to our management, we will charge an asset-based fee as described in Item 5 below. This poses a conflict of interest because we have an incentive to recommend a rollover to generate compensation rather than to act solely on the client’s needs. As a fiduciary, we are required to always act in the client’s best interests. Clients are under no obligation, contractually or otherwise, to roll over their retirement assets or to have their assets rolled into an IRA managed by us. Clients need to understand that many employer retirement plan sponsors permit former employees to keep their retirement assets in their company plan, even after they terminate employment or retire. When deciding whether to roll over employment retirement plan assets into an IRA or another investment vehicle, clients should consider the costs and benefits of each option. Employees will typically have the following options: • Leave the funds in the employer's (or former employer's) plan. • Move the funds to the new employer's retirement plan. • Withdraw the funds from the plan, which results in a taxable distribution and a taxable event. • Roll over the funds into an IRA rollover account. Before making any changes to their plan, we encourage clients to carefully consider any tax implications with their accountant or tax advisor. Below are some general 401K Plan features and differences versus an IRA that clients should take into account: • Although employer retirement plans may have a more limited investment menu than the options available in an IRA, the plan may also offer unique investment opportunities not available to the public, such as the ability to invest in the employer’s securities if the employer is publicly traded. • The employer retirement plan may offer financial advice, guidance, and/or model management or portfolio options at no additional cost or at a fee that may be lower than our advisory fee. • Clients should understand the various investments available in an IRA and the • costs. In some cases, the employer retirement plan may allow participants to hire us as investment managers and keep the assets titled in the plan’s name. • Clients interested in investing only in mutual funds should understand the cost structures of the share classes available in the employer's retirement plan and how those costs compare with those in an IRA. 6  • • It may be possible to take out a loan on 401 (k) plan assets. This option is not available for IRAs. It may be possible to delay taking minimum distributions from a 401 (k) plan or retirement account beyond age 73. • • A 401 (k) plan may offer more liability protection than a rollover IRA. Although IRA assets are generally protected from creditors in bankruptcy, this depends on state law, and there can be exceptions to the general rules. IRA distributions are subject to ordinary income tax and may also be subject to a 10% early distribution tax penalty unless they qualify for an exception. There are certain exceptions available based on age, disability, or if the assets are used to pay for higher education expenses or to purchase a home. Clients must understand the differences and options available, as well as the cost and tax implications, to be able to decide whether an IRA rollover is appropriate. Financial and Estate Planning Coordination We offer financial planning services to help clients define their personal financial needs, goals, and objectives, as well as estate planning coordination services to support clients with their estate planning needs. For clients requiring a simple estate plan, we offer an online platform that guides clients through a series of questionnaires. Based on their responses, the platform generates estate planning documents. Our role is limited to guiding clients through the document preparation process. We do not provide legal advice, and clients are strongly encouraged to review the final documents with their attorney. For clients with more complex estate planning needs, we provide referrals to qualified estate planning attorneys. Once documents are finalized, we also help clients coordinate periodic reviews, updates, and beneficiary changes. Assets Under Management As of December 31, 2025, FD Wealth has assets under management of $261,182,326, of which $173,904,787 are discretionary regulatory assets under management and $87,277,538 are non- discretionary assets. FD Wealth also managed $202,502,813 in assets under advisement, comprising variable insurance products, annuities, and 401(k) plans. For reporting purposes, annuity contracts are presented by contract value, and variable universal life contracts are presented by surrender value. Item 5: Fees and Compensation Asset-Based Fee The annual advisory fee is generally based upon a percentage of the market value of assets placed under our management and will not exceed 1.25%. Our current fee schedule for discretionary and non-discretionary portfolios is: Up to $10,000,000 1.25% $10,000,0001 to $25,000,000 1.00% $25,000,001 and up 0.75% 7  Our 401(k) plan fees are as follows: First $1,000,000 $1,000,001 to $2,500,000 $2,500,001 to $5,000,000 $5,000,001 t0 $10,000,000 $10,000,001 and up 0.75% 0.60% 0.50% 0.40% 0.30% Fees are charged quarterly in advance and are calculated on an account's asset value as of the last business day of the prior quarter. The market value is based on the custodian or other independent third party’s valuation and includes cash balances. The fee will be prorated for cash and securities deposited during the billing period. Clients should also be aware that other clients may have received negotiated discounts, and the same or similar investment services may be available from other investment advisers for a lower or higher fee. The fees paid to FD Wealth may be reduced for employee and family member accounts. For 401 (k)s, billing is handled by the recordkeeper or administrator. Billing is handled differently by each record keeper/administrator, as agreed to by the plan sponsor or fiduciary. Some recordkeepers/administrators bill monthly, while others bill quarterly or in advance, and may or may not prorate fees. FD Wealth will work with each plan recordkeeper/ administrator to accommodate their process. FD Wealth’s fee will be outlined in the Advisory Agreement for the plan and may be adjusted to cover certain expenses. The Investment Management Agreement authorizes us to deduct advisory fees from the client’s custodial account. The fees will be reflected in the client’s custodian account statements. We request that clients carefully review their custodian statements and inform us of any discrepancies. Typically, third-party management fees are included in FD Wealth’s fees except in situations in which specialized portfolios are selected, in which case the client will pay a separate management fee to the third- party manager, as outlined in the third-party manager’s fee schedule. Any additional fees will be fully disclosed to the client. FD Wealth does not receive any portion of the third-party manager’s fee. FD Wealth fees are exclusive and in addition to transaction fees, and other costs or expenses that shall be incurred directly by the client. Clients will generally incur certain charges imposed by custodians, brokers, and other third parties, such as fees charged by fund managers, custodial fees, set-up fees, termination fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic funds fees, and other fees and taxes on brokerage account and securities transactions. An asset-based fee may cost more than a transaction-based fee, but clients may prefer it if they want ongoing advice or for someone to make investment decisions on their behalf. Although FD Wealth believes the fees offered are competitive with other investment advisers, we make no guarantee that the cost of a particular program will be lower than that which may be available elsewhere. When appropriate, FD Wealth may recommend using margin and/or option transactions. Because these investment strategies involve a certain degree of additional risk, they are only recommended when consistent with the client’s objectives and risk tolerance. The use of margin also results in interest charges, in addition to all other fees and expenses associated with account management. Although account statements for margined accounts may reflect a negative amount, our advisory fee is based on the account’s absolute market value. This poses a conflict of interest because FD Wealth benefits by receiving a higher fee based on the account’s absolute market value. 8  In addition to FD Wealth’s advisory fee, each mutual fund or ETF in which a client's assets may be invested also charges its own management fees and other expenses. The specific fees and expenses are described in the respective fund’s prospectus. Depending on the fund, a client may be able to invest directly in the shares of a mutual fund, with or without incurring any sales charges or advisory fees. Mutual fund companies generally offer multiple share classes of the same fund. Share classes are described in the mutual fund's prospectus. Each share class charges different fees and expenses. Depending on the share class selected, fees and internal expense charges may be higher or lower. Certain funds do not charge a transaction fee but have higher internal expenses. Selecting funds with higher fees and expenses may adversely affect an account’s long- term performance. FD Wealth’s policy is to generally recommend that clients invest in the lowest-cost share class available, based on the client’s situation. FD Wealth usually recommends advisor- or institutional-share classes, which typically have the lowest expense ratios and are more beneficial than other share classes. Advisor or institutional share classes are generally available to investors in qualified fee-based advisor programs or accounts that meet specific minimum investment requirements. When deemed appropriate, we may recommend that a client who transfers in mutual fund holdings liquidate their existing holdings, which could result in tax consequences or the client having to pay contingent deferred sales charges or other redemption fees. Clients are encouraged to review the fees charged by the funds and our advisory fees to fully understand the total amount of fees to be paid. Please refer to the mutual fund's prospectus for additional information regarding a particular fund’s fees and expenses. Fees for Financial Planning and Estate Planning Coordination Our minimum hourly fee is $500. Clients are typically charged a fixed fee for financial planning and Estate Planning Coordination services. These services are invoiced separately. The cost depends on the scope and complexity of the work and will be outlined in the Financial Planning Agreement. Compensation on Insurance Product Sales One or more FD Wealth Investment Adviser Representatives are also licensed insurance agents and, when deemed appropriate, will recommend that FD Wealth clients purchase insurance products. The receipt of commissions poses a conflict of interest because the FD Wealth investment insurance agent has an incentive to recommend that clients purchase insurance products to generate commissions. In addition, as deemed appropriate, FD Wealth will recommend that clients purchase or exchange commission-free annuities to be managed by FD Wealth. This poses a conflict of interest because FD Wealth benefits from increased assets under management and a higher management fee. Clients are under no obligation to purchase insurance or securities products from FD Wealth or any particular individual, brokerage firm, insurance company, or service provider. They may purchase such products through a different insurance agent or provider. We manage these conflicts through disclosure, allowing clients to make informed decisions, and through policies and procedures that require us to act in the client’s best interests. 9  Fees for Retirement Plan Services under Dynamic For retirement plan services delivered through Dynamic, plan sponsor fees are generally billed by Dynamic, and FD Wealth receives a portion of such fees pursuant to its agreement with Dynamic. Termination The advisory relationship with FD Wealth can be terminated at any time, by either party, for any reason, upon 30 days’ written notice, as outlined in our Investment Management Agreement. Fees for accounts terminated during a calendar quarter will be refunded on a prorated basis. Item 6: Performance-Based Fees and Side-by-Side Management FD Wealth does not charge performance-based fees and does not participate in side-by-side management. Item 7: Types of Clients FD Wealth offers advisory services to individuals, high-net-worth individuals, trusts, estates, corporations, limited liability companies, and retirement plan sponsors. We typically require a minimum account size of $1,000,000. At our sole discretion, we may waive or lower the required account minimum for employee-related accounts, or on a case-by- case basis. Additionally, the third-party manager(s) we recommend may have minimum account requirements. FD Wealth’s advisers will discuss the specific requirements with clients. Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss FD Wealth designs investment advice based on the client’s investment objectives and goals. In formulating investment advice and our market outlook, we rely on various sources of information, including, but not limited to, third-party research materials, company press releases, annual reports, prospectuses, SEC filings, and credit ratings. Methods of Analysis We will, as deemed appropriate, use the following methods of analysis: • Fundamental Analysis - The review of a company’s financial statements, industry, market trends, and other factors to assess the company’s potential for future earnings growth. • Technical Analysis - The statistical analysis of price and volume patterns to predict a security’s future price movements or trends. There can be no assurance that fundamental or technical analysis will be accurate or achieve the intended goals. 10  Investment Strategies Used We will generally use the following strategies in managing client accounts: • Asset Allocation - The process of dividing an investment portfolio among different asset classes, such as stocks, bonds, cash, or cash equivalents, to reduce or manage risk. • Diversification - The process of dividing investments within asset categories to reduce or manage risk. • Rebalancing - The process of periodically rebalancing an investment portfolio back to the previously set asset allocation targets to maintain the predetermined investment allocation mix. Although FD Wealth will seek to implement strategies to minimize potential losses, there can be no assurance that these strategies will be successful, particularly in the short term, and clients may lose all or a substantial portion of their assets. Risk of Loss Investing involves the risk of loss that clients should be prepared to bear. Below is a general discussion of the different types of risks facing investors: Market Risk - The stock market as a whole, or the value of an individual company’s security, will fluctuate in value and cause the value of a client’s investments to increase or decrease. Market risk exists in all types of investments. Fixed Income Market Risk - The market price of debt securities will typically decrease or increase as interest rates rise or fall, which will cause the value of a client’s investments to increase or decrease. When investing in fixed-income securities, there is the risk that the issuer will default on the bond and be unable to make payments. Securities that credit rating agencies rate as below investment grade, also known as “high yield bonds” or “junk bonds,” involve a greater risk of default and loss of principal. Fixed-income investors who receive regular interest payments face the risk that inflation will erode their spending power. Credit/Counterparty Risk - The risk that the issuer or guarantor of a fixed income security, or the counterparty of a structured product or derivative contract, will default on its obligation to pay interest and/or principal, resulting in a loss to the investor. Liquidity Risk - The risk that if a particular security or instrument becomes illiquid, an investor may not be able to sell the position for an acceptable price or may not be able to sell it at all, resulting in a loss to the investor. Leverage - Leverage creates an opportunity for greater total returns but also carries a higher risk of loss due to adverse price movements and margin calls. Foreign Securities/Emerging Markets Risk - Foreign securities may involve additional risks due to political, economic, regulatory, and operational uncertainties and/or currency fluctuations. Clients should be aware that all these risks may be heightened in emerging markets. 11  Risk of Specific Types of Investments Different financial instruments have different levels of risk exposure and may, therefore, be inappropriate for a particular client’s circumstances or risk tolerance. Additional product and risk disclosures are included in the prospectus, offering documents or term sheets for the particular investment, or provided when investments are made. Brokered Certificates of Deposit - Brokered CDs typically have higher minimum investment requirements and longer maturities than traditional bank CDs. Unlike traditional bank CDs, periodic interest payments on Brokered CDs are not reinvested. Investors wishing to sell their Brokered CDs in the secondary market before maturity should be aware that liquidity in the secondary market can be limited, their CDs will be subject to market risk, and prices will fluctuate before maturity. It may be less than the CD’s face value. Additionally, the price of the CD will include accrued interest up to the settlement date. Although FD Wealth does not charge commissions on CD transactions, secondary market CDs will include a markup. FD Wealth does not guarantee the financial condition of the issuing bank. Brokered CDs are eligible for FDIC insurance up to $250,000 (including principal and interest) per account (individual, joint, IRA, etc.) and per issuing bank. Callable CDs give the issuing bank the option to terminate or call the CD before maturity. Investors in Callable CDs should be aware that, in a lower-interest-rate environment, their CD will likely be called before maturity, and the principal will be reinvested at a lower interest rate. Callable CDs tend to have longer maturities than traditional bank CDs and are subject to market risk. The market price of Callable CDs will fluctuate prior to maturity; therefore, investors should be prepared to hold their CDs until maturity or until they are called. Mutual Funds and ETFs - The risk of owning a mutual fund or ETF generally reflects the risks of the underlying securities it holds. Mutual fund and ETF investors should carefully review the respective mutual fund or ETF’s prospectus, which contains a description of the investment objectives, risks, fees, and expenses. Annuities - Variable annuities are complex financial products offered by insurance companies and regulated by state insurance departments and the SEC. Variable annuities are a type of annuity contract. A variable annuity differs from a fixed annuity in that it generally does not guarantee a specific interest yield from investments. The variable annuity's value is based on the performance of the underlying investment portfolio of subaccounts. Variable annuities are designed for long-term investing and are subject to market risk, including the risk of loss of principal. State insurance departments primarily regulate fixed annuities and not the SEC. Fixed-index annuities are annuity contracts that pay interest based on the performance of a specified market index, such as the S&P 500. While the interest rate credited to an indexed account is linked to the performance of an underlying index, premium payments made to a fixed index annuity are not directly invested in the stock market. However, certain provisions in these contracts can limit the potential upside to only a portion of the market’s rise. There are risks, fees, and charges associated with fixed index annuities. Before purchasing an annuity, clients should carefully review the prospectus, contract, or other offering documents from the insurance company that offers the annuity. These documents contain important information about the annuity's features, benefits, risks, fees, surrender charges, surrender periods, and other costs and expenses. 12  Alternative Investments - Investments in private funds, such as hedge funds or private equity, involve long holding periods, offer limited liquidity, and carry significant risk. These types of investments should only be assumed by sophisticated investors capable of bearing the risk of loss of all their investment. Before investing, prospective investors should carefully review the offering documents, which describe the risks, fees, and expenses. FD Wealth seeks to mitigate the above risks by monitoring markets, economic conditions, industries, and changes in the general outlook on corporate earnings; regulatory developments; central bank monetary policies; interest and currency rates; and adverse investor sentiment. However, there can be no assurance that a particular strategy will be successful or be able to avoid a loss. Investment performance of any kind is not guaranteed, and past performance is not an indication of future results. Other Risks Cybersecurity Risk: FD Wealth utilizes electronic communication networks and electronic media to maintain information about its clients and its business. This creates an inherent risk of cybersecurity incidents or cyberattacks that may result in the inadvertent disclosure of confidential and sensitive information to unintended parties, unauthorized access to such information, or operational disruptions caused by malicious hackers. We maintain technical and physical safeguards and take other reasonable precautions to safeguard the confidentiality of sensitive information and internal data, including periodic testing of our systems. However, even with reasonable precautions in place, the risk of cybersecurity incidents remains. FD Wealth has policies and procedures in place regarding information technology security. In the event of such an incident, we will promptly notify the affected parties and take all necessary and appropriate actions. Item 9: Disciplinary Information We are required to disclose legal or disciplinary events involving the firm or its employees that are material to the client’s evaluation of FD Wealth’s business or the integrity of its management. FD Wealth and its employees have not been the subject of any disciplinary proceedings, and at this time, FD Wealth has no information to report regarding this item. Item 10: Other Financial Industry Activities and Affiliations FD Wealth does not have an application pending with the SEC to register as a broker-dealer. FD Wealth does not control affiliates or related persons who are broker-dealers, investment advisers, or investment companies. Additionally, FD Wealth is not registered and has no application pending to register as a Futures Commission Merchant (FCM), Commodity Pool Operator (CPO), or Commodity Trading Advisor (CTA). Our relationship with FD National, an independent insurance agency, is material to our business. We have an agreement with FD National to provide certain administrative services. In addition, FD National will refer clients to us from time to time. We receive economic benefits from this arrangement. As noted, one or more FD Wealth financial advisers are licensed insurance agents, and each is also a registered representative of an unaffiliated broker-dealer. In this capacity, he receives 13  commission-based compensation for insurance and brokerage business. This is separate from FD Wealth’s advisory business and fees, and it poses a conflict of interest because he has an incentive to recommend brokerage and insurance products to earn commissions. Clients are under no obligation to purchase insurance or securities products from a particular individual, brokerage firm, insurance company, or service provider. We manage these conflicts through disclosure, allowing clients to make informed decisions, and through policies and procedures that require us to act in the client’s best interests. Fidelity Brokerage Services, LLC FD Wealth’s relationship with Fidelity Brokerage Services, LLC (“Fidelity”) is material to its business. Through its relationship with Fidelity, FD Wealth has access to custody, clearing and reporting services, an institutional platform, and a wide range of investment products and services, which assist FD Wealth in servicing client accounts. Fidelity also makes available to us other services, including market and pricing information, research, marketing support, practice management resources, access to educational conferences, and other benefits that assist FD Wealth in monitoring and/or servicing client accounts that we would otherwise have to pay for. Although FD Wealth believes that the arrangement with Fidelity is beneficial to our clients and our business, the receipt of economic benefits from Fidelity creates a conflict of interest because FD Wealth has an incentive to increase assets at Fidelity to reduce its expenses and receive those benefits. We manage this conflict through disclosure so that clients can make an informed decision. Clients may obtain custody and brokerage services from other service providers at higher or lower costs and are not obligated to use Fidelity's services. Clients may select a different custodian, provided it meets our due diligence and operational requirements. Dynamic Advisor Solutions, LLC FD Wealth has entered into a sub-advisory and service agreement with Dynamic Advisor Solutions, LLC (“Dynamic”), an unaffiliated SEC- registered investment adviser. The agreement provides FD Wealth with access to customized portfolios, research, and marketing support. FD Wealth pays Dynamic a fee for these services (the client is not charged). We believe that this agreement is beneficial to our clients and our business. FD Wealth has also entered into an agreement to provide Dynamic investment advisers and their clients with retirement plan consulting and support services on defined contribution retirement plans, including 401(k) employer-sponsored plans and 401(k) profit-sharing plans. The arrangements with Dynamic are material to its business. FD Wealth may be incentivized to recommend Dynamic to receive economic benefits. Additionally, because FD Wealth maintains a fee-paying relationship with Dynamic while serving as a liaison to Dynamic plan sponsors, FD Wealth could have divided loyalties in the event of disputes, service issues, or pricing concerns involving Dynamic and the plan sponsors. We manage these potential conflicts through disclosure so that clients can make an informed decision and through policies and procedures that require us to act at all times as a fiduciary and in the client’s best interests. As part of FD Wealth’s compliance program, the Firm will periodically assess external relationships and as applicable, will take steps to address any identified conflicts. 14  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading FD Wealth has adopted a Code of Ethics in compliance with Rule 204A-1 under the Advisers Act that describes FD Wealth’s fiduciary duty to its clients and the high standard of conduct expected of its employees. The Code of Ethics includes provisions relating to: • a prohibition on engaging in any fraudulent, deceptive, or manipulative practices, including insider trading; • procedures for maintaining the confidentiality of client information; reporting of certain gifts and business entertainment; • personal trading policies that require putting the client’s interests first; • preclearance of an employee’s participation in certain investments, such as initial public offerings or private offerings; reporting of personal securities holdings and transactions; and • • Reporting of Outside Business Activities or Interests. FD Wealth employees and Access Persons may buy or sell securities and other investments that FD Wealth also recommends to clients. The Code of Ethics provides that at all times, employees and Access Persons must act in the client’s best interests, and client orders must always take precedence. Neither FD Wealth nor any employees or Access Persons may recommend, buy, or sell for client accounts, or securities in which FD Wealth or an employee or Access Person has a material financial interest without prior disclosure to the client. Additionally, neither FD Wealth nor its management team is restricted from engaging in other business activities that may involve substantial time and resources away from FD Wealth. To minimize this conflict of interest, our employees and Access Persons are required to place clients’ interests ahead of their own and to adhere to FD Wealth’s Code of Ethics. FD Wealth has a fiduciary duty to act in the best interest of its clients. When an apparent or potential conflict exists, the interests of clients must take precedence over those of the Firm, its officers, and employees. Please refer to the Form ADV Part 2B Brochure Supplements for additional information about the involvement of our management and advisory personnel in other business activities. All employees must acknowledge and agree to abide by the terms of FD Wealth’s Code of Ethics and report any violations of the Code of Ethics to the Chief Compliance Officer. Failure to abide by the Code of Ethics will subject an employee to sanctions, which may include termination of employment. Clients may request a copy of our Code of Ethics by contacting us at info@fdwealth.net. Item 12: Brokerage Practices FD Wealth does not have discretionary authority to select the client’s custodian. We recommend that clients use Fidelity for custody, clearing and brokerage services. Clients are not obligated to use Fidelity's services and should be aware that custody, clearing and brokerage services may be available from other financial institutions at higher or lower costs. Clients may select a different custodian to safeguard their assets, provided that the custodian meets our due diligence and operational requirements. Clients authorize us to execute trades through the custodian’s brokers or other brokers we select. 15  Best Execution FD Wealth must seek “best execution” for client transactions. The SEC defines best execution as the “best qualitative execution,” not necessarily the lowest possible execution cost. In seeking the best execution, the determinative factor is not the lowest possible cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of the executing broker’s services, including the institution’s financial strength, reputation, soundness, execution capability, commission rates, and responsiveness. FD Wealth generally does not negotiate commissions on a trade-by-trade basis for its clients unless using a sub-advisor. Typically, the executing broker or custodian will determine those costs. Although executing brokers are subject to best execution obligations and will generally seek competitive commission rates, they are not obligated to choose the broker offering the lowest available commission rate if, in their reasonable judgment, a higher commission may be justified by the services provided by the broker, or by other factors such as those described above. As part of its fiduciary duty, FD Wealth will periodically evaluate the quality of brokerage services received and the quality and cost of services available from alternative brokers or venues. Soft Dollars and Referral Arrangements We do not receive client referrals from external brokers or financial intermediaries in exchange for directing client brokerage to them. Although FD Wealth has not entered into third-party soft- dollar arrangements with any external brokers, the Firm’s receipt of research from the client’s custodians, brokers, or financial intermediaries may be considered soft dollars. To the extent FD Wealth receives research, it will be used to benefit all clients. Trade Aggregation If no sub-advisor is being used, and when practical and appropriate, we may aggregate multiple client orders into a single trade. In an aggregated trade, all participants will receive an average price. If a partial execution is obtained, FD Wealth will generally allocate shares on a pro-rata basis or in a manner that is equitable to the clients involved. Allocation of Investment Opportunities From time to time, two or more accounts may seek to invest in the same securities or pursue a similar strategy. In such cases, FD Wealth will ensure that no account or group of accounts is favored or preferred over any other account or group of accounts. As a fiduciary, FD Wealth must at all times act in the best interest of all its clients. Directed Brokerage If a client asks us to direct transaction(s) to a specific broker or brokers for execution, we may be unable to achieve the most favorable execution. This can result in additional costs for the client. Principal and Cross Trades FD Wealth does not engage in principal trades or effect cross transactions for client accounts. 16  Trade Errors FD Wealth’s trade error policy is to restore the client’s account to its original position through a trade correction, trade cancellation, or adjustment so that clients are not adversely impacted. Item 13: Review of Accounts FD Wealth monitors client accounts on an ongoing basis for consistency of portfolio investments with objectives and risk tolerance, performance, allocations, and compliance with any reasonable investment restrictions. FD Wealth confirms the client’s investment objectives and selected investment profile at least annually. Clients are reminded to promptly notify us of any material changes to their financial situation or investment objectives, as these will affect the management of their accounts. Item 14: Client Referrals and Other Compensation Advisers Act Rule 206(4)-1 permits investment advisers to compensate solicitors (also known as referral agents or promoters), for client introductions or referrals. The Rule requires, among other things, that clients receive a disclosure document that describes the arrangement and the compensation paid to the solicitor. The fee payable to solicitors/referral agents may not result in any additional charge to clients introduced by the solicitor/referral agent. FD Wealth will pay a referral fee to employees of its affiliate, FD National, who refer clients to the Firm. From time to time, FD Wealth may also refer clients to FD National. Each affiliate benefits from additional business generated by the referrals. Clients are not obligated to use FD National's services and may select a different benefits or insurance provider. As discussed under Item 4 above, under the retirement plan services arrangement with Dynamic, FD Wealth receives a portion of the fees Dynamic collects from plan sponsors. Although clients do not incur additional fees under this revenue-sharing arrangement, it creates several conflicts of interest as described in Item 4 above, because FD Wealth has an incentive to recommend services involving Dynamic. Item 15: Custody FD Wealth’s limited ability to instruct the client’s custodian to deduct advisory fees from its client’s accounts results in FD Wealth being deemed to exercise “custody” over client assets. We do not accept physical custody of the client’s funds or securities or engage in activities that would subject the firm to the provisions of Advisers Act Rule 206(4)-2 (the Custody Rule). The client’s cash and securities are maintained at banks, broker-dealers, or other financial institutions that serve as the client’s custodian. We are also deemed to have custody of clients’ assets in situations where we have discretion over third-party transfers under Standing Letters of Authorization (SLOA). The SEC has issued a no-action letter providing relief from certain Custody Rule requirements if we comply with the safeguards outlined in the letter. At this time, we don’t have any SLOA instructions but may receive such instructions in the future and intend to comply with such safeguards. The client’s custodian(s) are required to send account statements directly to clients at least quarterly. The custodian(s) also offer clients online access to their accounts. The custodian account statements will show all account activity and transactions during the period, including beginning and ending balances, current values and holdings, and the amounts deducted from the 17  client’s account to pay our advisory fees. FD Wealth encourages clients to carefully review the custodian account statements and promptly notify us of any discrepancies or errors. Item 16: Investment Discretion For discretionary accounts, the Investment Management Agreement provides FD Wealth with limited authority to determine, without obtaining the client’s specific consent, the third-party manager to be used, the securities to be bought or sold, the amount of the securities to be bought or sold, and the broker to be used to execute transactions. Clients may limit our discretionary authority by imposing reasonable investment restrictions, limiting the types of securities that can be purchased for their accounts. FD Wealth will exercise this discretionary authority in a manner consistent with each client’s stated investment objectives. For non-discretionary accounts, we provide investment advice, formulate strategies, and evaluate account performance, but we are required to obtain the client’s approval before placing any transactions. Consequently, if we are unable to reach the client to obtain the client’s consent to execute a particular recommendation or strategy, the investment opportunity may no longer be available at the desired price. Item 17: Voting Client Securities FD Wealth does not have the authority to vote proxies on behalf of advisory clients. Clients are responsible for voting proxies for all securities held in their portfolios. The client’s custodian will mail all correspondence related to proxies, class action lawsuits, legal proceedings, bankruptcies, and proceedings involving the issuer of the securities held in the client’s account directly to each client. Any required action is the client's responsibility. FD Wealth may provide general information and answer general client questions regarding proxy voting, to the extent the Firm has relevant knowledge or information. Please contact us at info@fdwealth.net to obtain a copy of our Proxy Voting Policy. Item 18: Financial Information We are required to provide clients with certain financial information or disclosures about the adviser’s financial condition. As of the date of this Brochure, FD Wealth has no financial commitments or liabilities that could impair our ability to manage client accounts and meet our contractual obligations to clients. FD Wealth and its management have not been the subject of any bankruptcy or other proceeding that could affect their financial condition. 18