FULCRUM WEALTH ADVISORS, LLC

Firm Disclosure and Privacy Policy January 26, 2026 This Brochure provides information about the qualifications and business practices of Fulcrum Wealth Advisors, LLC (“Fulcrum”). If you have any questions about the contents of this Brochure, please contact us at 844-621-0630. 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. Fulcrum is a registered investment adviser. Registration as an investment adviser does not imply any level of skill or training. information about Fulcrum is available on the SEC’s website at Additional www.adviserinfo.sec.gov. Please refer to CRD# 169277 when researching our firm. Fulcrum Wealth Advisors, LLC 10940 NE 33rd Place, Suite 210 Bellevue, WA 98004 jim.falcone@fulcrumwa.com www.fulcrumwa.com 844-621-0630 1  Item 2 - Material Changes We are required to advise clients and prospective clients of any material changes to this Form ADV Part 2A Brochure since our last annual update. Since our last annual update in February 2025, we no longer have any investment advisor representatives who have dual registrations with an unaffiliated broker-dealer or other investment adviser. This reduces certain conflicts of interest present with such dual registrations, and we have removed these references throughout this Brochure. Clients will receive an annual summary of any material changes to this and subsequent brochures no later than 120 days after our fiscal year-end of December 31. At that time, we will offer either a full copy of our most current brochure or details related to all material changes, along with an offer to provide a full copy of our current brochure. If you would like additional information about Fulcrum Wealth Advisors, LLC, please contact us at 844-621- 0630, or visit the SEC’s website at www.adviserinfo.sec.gov. 2  Table of Contents Item 2 - Material Changes ............................................................................................................................. 2 Item 4 - Advisory Business............................................................................................................................ 4 Item 5 - Fees and Compensation .................................................................................................................. 6 Item 6 - Performance Based Fees ................................................................................................................ 8 Item 7 - Types of Clients ............................................................................................................................... 8 Item 8 - Methods of Analysis, Investment Strategies and ............................................................................. 8 Item 9 - Disciplinary History ........................................................................................................................ 10 Item 10 - Other Financial Industry Activities and Affiliations ....................................................................... 10 Item 11 - Code of Ethics, Participation or Interest in Client Transactions, Personal Securities Accounts . 10 Item 12 - Brokerage Practices..................................................................................................................... 11 Item 13 - Review of Accounts ..................................................................................................................... 14 Item 14 - Client Referrals and Other Compensation ................................................................................... 14 Item 15 - Custody ........................................................................................................................................ 14 Item 16 - Investment Discretion .................................................................................................................. 15 Item 17 - Voting Client Securities (Proxy Voting) ........................................................................................ 15 Item 18 - Financial Information.................................................................................................................... 15 Fulcrum Wealth Advisors - Privacy Policy .................................................................................................. 15 3  Item 4 - Advisory Business Fulcrum Wealth Advisors, LLC, (“Fulcrum,” “we,” “our,” “us”) is a Washington state limited liability company owned and operated by Jim Falcone; he is the sole owner. Fulcrum was started in 2013 to provide personalized and independent investment management services to clients and institutions. It is important for you to provide your representative with information on your investment goals. And, if possible, provide the approximate time before you will need to use your investments. Our representatives will educate themselves about your investment objectives and time horizon through a variety of means, primarily through direct interviews or questionnaires. Wealth Management Your representative will provide investment management services on a discretionary basis for a fee based on a percentage of assets under management. Your investments will be tailored to match your objectives and time horizon. In some cases, Advisor may utilize a separate and unaffiliated registered investment advisor (“Independent Manager”) to assist in the management of your Account. You, as the client, may place restrictions on the specific securities or types of securities used in your Account. You must notify us in the advisory agreement (“Agreement”) you sign with Fulcrum or later in writing. In connection with our investment management services, we also provide wealth management based on client needs. Wealth management services include macro-economic analysis, investment research, ongoing financial planning, retirement planning, quarterly performance reporting, consulting about other areas of financial life, such as tax issues, real estate considerations, or philanthropic advice. Because services are provided based on individual client circumstances, not all wealth management clients will receive all wealth management services. Financial Planning & Consulting We provide a variety of financial planning and financial consulting services, including the Wealth Management services described above, but offered as a standalone service without investment management. Comprehensive Consulting for Investors Managing Their Own Money This service is best for clients who want to handle their own investments, including all trade execution and rebalancing, but who want ongoing help with the financial planning and research elements of investing. We provide ongoing financial planning, macro-economic analysis, investment research, annual plan review, quarterly reviews, and specific product or other financial reviews, as appropriate for the client. One-Off Consulting For clients looking for one-time advice in a specific area, we offer consulting for an hourly fee. These services typically fall into the areas of financial planning, portfolio reviews, insurance reviews, or tax consulting (tax consulting does not involve tax return preparation—it is focused on client-specific issues common to investing scenarios and options; we encourage you to consult your own tax adviser to confirm the application of our advice to your specific situation). ERISA Plan Consulting We offer ERISA plan consulting to help clients manage their 401(k) or other self-directed retirement accounts that are not managed through our firm. Clients seeking this service will sign up with a third-party provider, Plan Confidence, that provides data on investment costs, options, and investment allocation based on the client’s investment profile, time horizon, and risk tolerance. We are available to offer macro- level investment advice and context for your retirement assets, including potential allocation decisions, but we do not implement any transactions. Clients are responsible for executing all transactions or rebalancing their retirement plan assets directly through the plan’s investment portal. General Information on Financial Plans If you receive a written plan, it makes an attempt to provide you with an estimate of future growth in your net-worth and income. All tax sensitive reports are provided to you as estimates of future income and 4  estate tax liabilities. These tax sensitive reports are based on current federal and applicable state laws regarding taxation. Federal and State Tax Laws are subject to change and interpretation. All reports, financial statement projections, tax liability estimates, and analysis are intended exclusively for your use in developing and implementing your financial plan. In view of this limited purpose, un-audited data is collected and used to produce your financial plan, therefore, any report, financial statement or analysis is to be considered un-audited as well. Accordingly, you should understand that such financial statements cannot be used as a representation of wealth, to obtain credit, or for any other purpose, other than developing a financial plan. Fulcrum will not audit (examine), review or compile such statements and accordingly, we will not express an opinion or other form of assurance on these financial statements, including the reasonableness of assumptions and other data on which any financial statements or projections are based. There will be differences between projected estimates and the actual results of the plan, because events and circumstances frequently do not occur as expected. Investment returns in particular are most volatile and the probability of estimates coming close to actual results declines with a reduction in the investment- holding period. We do not in any way represent or imply that the investment returns will be similar to estimates projected in your financial plan. The estimates reflect the historical returns of the various asset classes, and the past performance of these asset classes does not guarantee that future results of these asset classes or your investments will be similar. Fulcrum uses a proactive investment strategy; therefore, the actual returns of your portfolio will differ from the financial plan projections. The financial plan is highly dependent on certain economic assumptions about the future. Therefore, the client should establish familiarity with historical data regarding key assumptions such as inflation and investment rates of return, as well as an understanding of how significantly these assumptions affect the results of our analyses. We will not express any assurance as to the accuracy or reasonableness of your specific data and your assumptions. You are ultimately responsible for the assumptions and personal data upon which our procedures and projections are based. The financial plan assumptions and reports are primarily a tool to alert clients to certain possibilities. The reports are not intended to provide any guarantee about future events, including an individual’s investment returns. The implementation of the plan is solely your responsibility. The financial plans provided for some of our clients do not address all potential aspects of financial planning. Typically, our plans address retirement planning, college funding, and estate planning. Risk management issues such as life, health, disability, and long-term care insurance are not always addressed in every financial plan, and you are encouraged to ask specifically about these issues. Our financial plans are not intended to nor should they be considered to be advice about law or your legal rights and responsibilities, accounting or tax planning, the avoidance of tax penalties or interest or preparation of your tax return. You are encouraged to seek competent legal and tax advice before implementing any recommendation made in a written financial plan. Boeing employees receive complementary areas of financial planning or receive a waiver from being charged the hourly rate Fulcrum typically charges. When we recommend that you rollover retirement assets or transfer existing retirement assets (such as a 401(k) or an IRA) to our management, we have a conflict of interest. This is because we will generally earn additional revenue when we manage more assets. In making the recommendation, however, we do so only after determining that the recommendation is in your best interest. Further, in making any recommendation to transfer or rollover retirement assets, we do so as a “fiduciary,” as that term is defined in ERISA or the Internal Revenue Code, or both. We also acknowledge we are a fiduciary under ERISA or the Internal Revenue Code with respect to our ongoing investment advisory recommendations and discretionary asset management services, as described in the advisory agreement we execute with you. To the extent we provide non-fiduciary services to you, those will be described in the advisory agreement. Assets Under Management As of December 31, 2025, Fulcrum had $208 million under management, all on a discretionary basis. 5  Types of Investments Used We consider many different types of securities when formulating the investment advice we give to you, and do not provide advice only limited security types. If you come to us with existing investments, we evaluate them with respect to your financial goals, risk tolerance, and investment time horizon. Depending upon your situation, your account(s) managed by us may contain individual stocks, corporate and/or government bonds, mutual funds, or exchange traded funds (“ETFs”). In some situations, we may recommend that real estate-focused securities be part of your investment portfolio. We may also recommend direct participation programs (DPPs), business direct companies (BDCs), structured notes, and non-traded REITs. Negatively Correlated Investments We may invest a portion of your portfolios in negatively correlated mutual funds or ETFs. Negatively correlated mutual funds or ETFs may rise in value while the general stock market declines and vice versa. We may add these negatively correlated mutual funds or ETFs in an attempt to reduce the volatility of your portfolio. The addition of negatively correlated investments does not in any way guarantee that the volatility, draw down, or loss of portfolio principal will be lower, and it may actually reduce long-term portfolio performance. Selection of Other Advisors In some situations, we recommend that all or a portion of a client’s investment portfolio be actively managed by another investment advisor(s). These other advisors are reviewed and recommended by us to provide clients with expertise in a particular investment style, market segment or investment strategy. We consider your individual circumstances, needs, and objectives and recommend other advisors when recommending other advisors. The other advisors managing portions of your portfolio will charge a fee for these services and these fees are distinct, separate, and in addition to, the fees we charge. Our fees remain the same regardless of which managers we select on your behalf. A detailed description of the other advisors’ services and fees is provided in their disclosure brochure. Our role is to oversee these other advisors to assure they perform their services as expected. If we recommend, and you choose to use, another advisor(s) to manage all or a portion of your portfolio you will enter into an agreement with discloses the manager(s) and the additional fees you will pay. Item 5 - Fees and Compensation In most situations, the fees for services will be based on the amount of assets you have managed by Fulcrum. You will sign an advisory agreement that will describe the investment management services to be provided by Fulcrum, as well as the fees charged. Your advisory fees will be automatically deducted by Fulcrum from your accounts on a quarterly basis. The fee will be charged in advance, meaning that the fee will be collected at the beginning of the quarter. The fee will be a percentage of the value of all assets in the Account(s) at the beginning of the calendar quarter. The fee is calculated by multiplying the Account(s) value (including all positions in the account, cash, declared and paid dividends, accrued income and interest payments) of the assets at the beginning of the calendar quarter by one-quarter of the Annual Advisory Fee as noted in your Agreement. All fees charged by Fulcrum for investment management services are separate and distinct and in addition to the fees and expenses charged by mutual funds and exchange traded funds (ETFs). In these cases, the fees and expenses are described in each fund's prospectus. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. Accordingly, you should review both the fees charged by the funds/ETFs, custodian, Independent Managers and the fees charged by Fulcrum to fully understand the total amount of fees to be paid. Additionally, the investments selected for you are not exclusively available to Fulcrum and could be obtained through other firms. 6  The fees to be charged are shown on the advisory agreement but the standard advisory fee rates are as follows: Assets Managed $0 to $2,000,000 $2,000,001 to $5,000,000 $5,000,001 to $15,000,000 $15,000,001 and up Fee Rate 1.25% 1.10% 1.00% negotiable Financial Planning & Consulting Fees Wealth Management clients typically receive our Financial Planning & Consulting services in connection with the asset-based fees described above. Accordingly, the fees described in this section typically apply to clients who wish to engage us for a financial plan without an Investment Management relationship. In some cases, such as for very complex or unusual projects, we may enter into a separate consulting agreement with a Wealth Management client, but the scope and fees would be made explicit in a separate agreement. Except as noted, Fees for Financial Planning & Consulting are based upon the amount of time it takes to complete your plan or provide the consulting services at an hourly rate of $350 per hour. We provide ERISA Consulting Services for $20 per month (no hourly fee). Comprehensive Consulting for Investors Managing their Own Money is offered for $350 per hour. The Financial Planning & Consulting agreement (“Planning Agreement”) you sign with Fulcrum will describe the services to be provided and our estimate of the time to complete your plan. Fees may be lowered or waived depending on the client and the complexity of the plan or the clients’ investment sophistication level. In addition to Fulcrum’s Advisory Fees, you are also responsible for the transaction charges, fees and other expenses charged and imposed by the firm who holds your assets (Custodian). In the event you or Fulcrum terminates the advisory agreement during a quarter, the fee will be rebated for the portion of the quarter where services were not provided. Asset based fees are pro-rated based upon the number of days the account was under our management. Hourly fees are charged based upon the number of hours actually expended on the financial plan. The termination date used is the date Fulcrum or Client notifies the other party in writing (to address of record) of the termination. In the event the account is not available for electronically debiting the fee, Advisor will send a check to the most recent address of record for the Client. You may terminate this agreement within five (5) business days of the effective date of your agreement without any penalty or fees. Each time our fee is directly deducted from client accounts, we will send the qualified custodian notice of the amount of the fee to be deducted from your account. Third-Party Manager Fees In addition to the fees you pay to Fulcrum, if all or a portion of your portfolio is managed by one or more third-party managers, you will pay additional fees to that manager. These fees are charged as a percentage of your assets under management and will be disclosed in a written Schwab Agreement. Additional Compensation Fulcrum does not receive any additional compensation outside of our advisory fees. However, representatives of our firm may receive additional compensation through sales of insurance products. See Item 10 of this Brochure and your representative’s ADV Part 2B Brochure Supplement for additional information about such outside business activities, the additional compensation, and the conflicts of interest inherent in such recommendations. 7  Item 6 - Performance Based Fees Fulcrum does not manage advisory services in a performance-based fee structure. Fees are calculated based on the value of your assets in your managed accounts. We provide investment advisory services to other clients in addition to you. Not all clients receive the same investment advice, nor do they pay the same fee. We will act in the best interests of each of our clients at all times. Item 7 - Types of Clients Fulcrum clients are individuals with trust accounts, retirement, and non-retirement assets. Clients also consist of banks, ERISA pension and profit-sharing plans, corporations, estates and charitable organizations. The minimum account size for an advisory account client is $25,000, although this may be waived in special situations such as for referrals from existing clients. Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss While the methods of analysis are constantly evolving, many decisions and recommendations are made using the following:  Quantitative Analysis: An analysis technique that seeks to understand behavior by using complex mathematical and statistical modeling, measurement, and research. By assigning a numerical value to variables, quantitative analysts try to replicate reality mathematically. Some believe that it can also be used to predict real-world events, such as changes in a share price.  Qualitative Analysis: Securities analysis that uses subjective judgment based on non-quantifiable information, such as management expertise, industry cycles, strength of research and development, and labor relations. This type of analysis technique is different from quantitative analysis, which focuses on numbers. The two techniques, however, are often used together.  Modern Portfolio Theory – is the process of maximizing the expected return of the portfolio for a given amount of portfolio risk.  Technical Analysis – is the discipline of using historical price movement in an attempt to identify  market trends and to ascertain how long the trend may last. Investment Scoring Analysis – Fulcrum may employ a proprietary or a third-party system that scores investments based on quantitative methods. This scoring may be used in the analysis of investments to a desired performance level. Fulcrum and your representative have the ability to construct your portfolio using a wide variety of investments, including stocks, bonds, exchange traded funds, mutual funds, closed end funds, unit investment trusts, Independent Managers, options and other investments available through the brokerage firm where your assets are held in custody. Additionally, a large cash position may be utilized, the value of which is included in the calculation of your advisory fee. Various investment strategies may be used: Long Term Purchases – investments purchased with the expectation to hold the position over a long period of time, typically longer than one year. Short Term Purchases – investments purchased with the expectation that they will be quickly sold within a short time period. Margin Transactions – a transaction where you would borrow money to purchase a security and the underlying position is used as collateral on the loan. Options – an investment that that involves buying a right to purchase or sell a security at a specific price for a specified time. Investing has various risks as all investments have the risk of losing value. Some investments have the risk of defaulting on interest or principal payments. Investors are also faced with the risk that inflation will outpace the returns of the investment, which lowers the purchasing power for the investor. Rebalancing your portfolio may have an impact on your tax status, which could increase your tax obligation. Investing in options incurs the risk of expiration as well as loss of value over time. It is important that you understand that there are numerous risks associated with your investments. Please discuss any investment risk concerns you have with your Fulcrum representative and any tax concerns with your tax consultant. 8  Margin Transactions If you request, we can help you establish your account to allow for margin transactions. Margin allows you to purchase investments for your portfolio with money borrowed from your custodian and secured by the investments in your brokerage account. This allows you to purchase more stock than you would be able to with your available cash and allows us to purchase stock without selling other holdings. Therefore, your exposure to market volatility increases. In a declining market your account could experience greater losses. Derivatives Risk The use of derivatives such as options can lead to losses, including those magnified by leverage, particularly when derivatives are used to enhance return rather than offset risk. Liquidity Risk Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. Unregistered securities are also not liquid. Certain instrument, such as non-traded REITs or some DPPs may have no readily available market or third-party pricing. Structured notes usually have a limited secondary market and are often relatively illiquid. Reduced liquidity may have an adverse impact on market price and the ability to sell particular securities when necessary to meet cash needs or in response to a specific economic event, such as the deterioration of creditworthiness of an issuer. Reduced liquidity in the secondary market for certain securities may also make it more difficult to obtain market quotations based on actual trades for the purpose of valuing the security. Clients should invest in structured notes, private securities, and other illiquid (or relatively illiquid) assets only to the extent they have adequate other liquid assets available to fund current and ongoing cash requirements. Options In some, but not all cases, Fulcrum may use option contracts on securities in your managed portfolio. Option strategies are not used in all client portfolios. The use of option strategies is not always successful at increasing return or reducing losses. The use of options adds risk and cost to the portfolio. Option strategies can diminish account performance. Negatively Correlated Investment Risk Negatively correlated investments are designed to perform in a manner opposite to that of a particular market index, on a given day (i.e., go up when the market index goes down). The investments do not guarantee any specific performance and may fail to achieve their goal. If these investments are held for more than one day, their performance will diverge from their goal because of internal factors. Interest Rate Risk An increase in interest rates may cause the value of fixed income securities and funds that hold these securities to decline in value. Securities with longer durations tend to be more sensitive to interest rate changes, usually making them more volatile than securities with shorter durations. To the extent that your account is invested in fixed income securities with longer-term durations or funds holding these securities, rising interest rates may cause the value of these investments to decline significantly. Financial Planning Risks Financial planning services often require that assumptions about the future be made in order to incorporate forecasts into plans for the future. These assumptions might include but not limited to: future interest rates, inflation, investment performance, your longevity and health. As with all forecasts, actual results will be different than estimates. A risk exists that there will be material differences between the assumptions used in a plan and the actual results. In some cases, these differences will mean that potential results discussed in a plan will not be achieved. Alternative Investment Risks Other alternative investments, such as structured products and REITs, leasing programs, and mutual funds or ETFs that utilize alternative investment strategies, expose clients to heightened levels of liquidity, credit, interest rate, and counterparty risks. 9   REITs and alternative funds are offered by prospectus, Private Placement Memorandum, or other offering materials provided by the issuer. Fulcrum does not participate in the preparation of these materials and does not independently verify the issuer’s representations.  Structured products are a type of investment designed to meet financial needs identified by Fulcrum. Structured products are issued by large financial institutions and involve customizing the product mix to adhere to specific risk tolerances and performance objectives. Structured products are often created by varying the amount of exposure to volatile investments and often include the use of derivatives. Performance terms and features are spelled out in advance; delivery on the performance is highly dependent on the solvency of the issuer. The products usually can be traded on the secondary market but there is limited demand, and the sponsor is in most cases the only market maker. This means that selling prior to the maturity date may result in proceeds that are materially less than the original amount invested. See Liquidity Risk for more information.  Unregistered securities are offered through a Private Placement Memorandum or other offering materials and related subscription materials. They are available only to accredited investors, as that term is defined in Regulation D of the Securities Act of 1933.  Alternative offering materials contain important information about the substantial risks of investing in these securities, as well as details concerning fees, compensation, and conflicts of interest. We urge clients to review these materials carefully and to discuss any questions or concerns with their representative. Item 9 - Disciplinary History Fulcrum is required to disclose material facts regarding legal or disciplinary events that would be material to an evaluation of Fulcrum or its representatives. Fulcrum has not been the subject of any such event and has nothing to report in this Item. Item 10 - Other Financial Industry Activities and Affiliations As noted above in Item 5, some of Fulcrum’s investment advisory representatives may also recommend insurance products. When a Fulcrum client purchases an insurance product, the client will pay the premium or commission on those assets that are separate, distinct, and in addition to any advisory fees paid on advisory assets. This creates a conflict for the representative to sell a product to make a commission rather than because it’s in your best interest. To address these conflicts, we review the costs and expenses associated with insurance products recommended to you to ensure that the costs are reasonable and consistent with the fees you’d pay through unaffiliated insurance agents. We also disclose the conflict and make sure you understand that you are not obligated to purchase insurance products through our representatives and can implement recommendations through other, non-affiliated producers. Finally, we ensure that the recommendations we make as an investment advisor are consistent with our fiduciary duty to act solely in your interest. Item 11 - Code of Ethics, Participation or Interest in Client Transactions, Personal Securities Accounts We have adopted a code of ethics designed to prevent and detect violations of securities rules by our employees. Our controls in this area focus upon securities transactions made by our employees that have access to material information about the trading done by Fulcrum on behalf of clients. We will provide a copy of our code of ethics to clients or prospective clients upon request. It is the policy of Fulcrum to permit its employees and representatives to buy, sell, and hold the same securities that the representative also recommends to clients. It is acknowledged and understood that Fulcrum performs investment services for various clients with varying investment goals and risk profiles. As such, the investment advice may differ between clients. Fulcrum will have no obligation to recommend for purchase or sale a security which Fulcrum, its principals, affiliates, employees, or representatives may purchase, sell, or hold. When a decision is made to trade a security from all applicable accounts, priority is typically given to the client’s orders, although there are no internal trading rules that state the client orders 10  must be before or after trades of a representative. This may result in different execution prices for the client that may be higher or lower than the price received or paid by the representative. Item 12 - Brokerage Practices Recommended Broker/Custodian Fulcrum does not maintain custody of the assets we manage, though we may be deemed to have custody if you give us authority to withdraw assets from your account under certain circumstances (see Item 15, below). Your assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. Fulcrum currently recommends the custodial and brokerage services of Charles Schwab & Co., Inc. (“Schwab”) a registered broker-dealer and member SIPC. We are independently owned and operated and are not affiliated with Schwab. While we recommend Schwab as custodian/broker, clients will decide whether to do so and will open accounts with Schwab by entering an account agreement directly with them. We do not open accounts for clients, though we may assist in doing so. How We Select Brokers/Custodians We seek to recommend a custodian/broker that will hold client assets and execute transactions on terms that are, overall, most advantageous when compared with other available providers and their services. We consider a wide range of factors, including:  Combination of transaction execution services and asset custody services (generally without a separate fee for custody)  Capability to execute, clear, and settle trades (buy and sell securities for the account)  Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.)  Breadth of available investment products (stocks, bonds, mutual funds, ETFs, etc.)  Availability of investment research and tools that assist us in making investment decisions  Quality of services  Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate prices  Reputation, financial strength, security, and stability  Dedicated service team and local personnel  Prior service to us and our clients  Availability of other products and services that benefit us, as discussed below We have determined that having Schwab execute most trades is consistent with our duty to seek “best execution” of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. Your Brokerage and Custody Costs Schwab generally does not charge clients separate for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. Schwab is also compensated by earning interest on the uninvested cash in accounts or on any margin balance maintained in Schwab accounts, and from other ancillary services. Most trades no longer incur commissions or transaction fees, though there are exceptions. Schwab discloses its fees and costs to clients and we take those costs into account when executing transactions on your behalf. Schwab charges you a flat dollar amount as “prime broker” or “trade away” fee for each trade that we have executed by a different broker-dealer but where the securities bought or the funds form the securities sold are deposited (settled) into your Schwab account. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. Because of this, in order to minimize your trading costs, we have Schwab execute most trades for your account. Certain mutual funds and ETFs are made available for no transaction fee; as a result the confirmation may 11  show “no commission” for a particular transaction. Typically the custodian (but not Fulcrum) earns additional remuneration from such services as recordkeeping, administration, and platform fees, for the funds and ETFs on their no-transaction fee lists. This additional revenue to the custodian will tend to increase the internal expenses of the fund or ETF. Fulcrum selects investments based on our assessment of a number of factors, including liquidity, asset exposure, reasonable fees, effective management, and low execution cost. Where we choose a no-transaction fee fund or ETF, it is because it has met our criteria in all applicable categories. Products and Services Available to Fulcrum from Schwab Schwab Advisor Services is Schwab’s business serving independent investment advisory firms like us. They provide Fulcrum and our clients with access to their institutional broker services (trading, custody, reporting, and related services), some of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available without our requesting them and at no charge to Fulcrum. Following is a more detailed description of these services: Services that Benefit Clients Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. These services general benefit you and your account. Services that May Not Directly Benefit Clients Schwab also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or a substantial number of our clients’ accounts, including If we had accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that:  Provide access to client account data (such as duplicate trade confirmations and account statements)  Facilitate trade execution and allocate aggregated trade orders for multiple client accounts  Provide pricing and other market data  Facilitate payment of our fees from our clients’ accounts  Assist with back-office functions, recordkeeping, and client reporting Services that Generally Benefit Only Fulcrum Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include:  Educational conferences and events  Consulting on technology, compliance, legal, and business needs  Publications and conferences on practice management and business succession  Access to employee benefits providers, human capital consultants, and insurance providers  Marketing consulting and support  Occasional business entertainment of our personnel Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. We make limited use of the services in this section. We are most likely to use compliance and technology consulting and to attend conferences and other educational events, 12  some of which include business entertainment. Fulcrum’s Interest in Schwab’s Services The availability of these services from Schwab benefits us because we do not have to produce or purchase them, and we don’t have to pay Schwab for them. This creates an incentive for us to recommend that clients maintain their accounts with Schwab, based on our interest in receiving Schwab’s services that benefit our business rather than based on clients’ interest in receiving the best value in custody services and the most favorable execution of their transactions. While this incentive creates a conflict of interest, we believe that our selection of Schwab as custodian and broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services (see “How We Select Brokers/Custodians”) and not Schwab’s services that benefit only us. Research and Other Soft Dollar Benefits We do not have any traditional “soft dollar” arrangements in place, in which we agree to direct a certain amount of commission dollars to a specific custodian in exchange for research or other services. Rather, the services described in this Item 12 are made available to us simply because we maintain client accounts on the Schwab platform. Many of these services generally may be used to service all or a substantial number of Fulcrum' accounts, including accounts not maintained at Schwab. The availability to Fulcrum of the foregoing products and services is not contingent upon Fulcrum committing to Schwab any specific amount of business (assets in custody or trading commissions). In some cases, clients could pay more for custody and execution through the custodian we recommend than through others. We review the capacities and costs of Schwab regularly to ensure that our clients are receiving quality executions and competitive pricing, as well as more intangible service benefits. Directed Brokerage Because we recommend Schwab and then execute transactions through that custodian on a discretionary basis, we are effectively requiring that clients “direct” brokerage to Schwab, absent other specific instructions as discussed below. Because we are not choosing brokers on a trade-by-trade basis, we may not be able to achieve the most favorable executions for clients and this may ultimately cost clients more money. Not all investment advisers require directed brokerage. We do not use, recommend, or direct activity to brokers (including Schwab) in exchange for client referrals. Fulcrum does not generally permit clients to direct us to use brokers other than the custodian. If we agree to accommodate a request to do this, we will likely have little or no ability to negotiate commissions or influence execution price, and the client will also not benefit from the savings afforded by the occasional trade aggregation we may implement for other clients. This may result in greater costs. Aggregation of Trades Fulcrum does not generally aggregate client trades. Transactions for each client account generally will be effected independently, unless we decide to purchase or sell the same securities for several clients at approximately the same time. As a result, certain client trades may be executed before others, at a different price and/or commission rate. Additionally, our clients may not receive volume discounts available to advisers who routinely aggregate client trades. Fulcrum may (but is not obligated to) aggregate client trades to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among Fulcrum’ clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among clients in proportion to the purchase and sale orders placed for each client account on any given day. Fulcrum will not receive any additional compensation or remuneration as a result of such aggregation. 13  Third Party Managers As described in Item 4, above, in some cases we may select third-party managers to advise on a portion of client assets. These managers will generally place all transactions through the client’s account at Schwab, subject to the managers’ obligation to seek best execution. Because Schwab charges fees for transactions placed with outside brokers (see Your Brokerage and Custody Costs, above), outside equity managers will typically select Schwab as the broker who provides the best execution on a specific transaction after weighing possible price improvement versus the trade-away fee. However, managers may choose to trade away from Schwab when they believe (in their sole determination) that doing so is in the client’s best interest. As a result, in addition to any trade-away fee charged by Schwab, clients may pay an additional fee to the broker/dealer used for execution. Also, when beneficial to the client, individual fixed income transactions may be effected through broker- dealers with whom the third-party manager has entered into arrangements for prime brokerage clearing services. In these cases, clients may also incur “trade-away” fees. Item 13 - Review of Accounts Accounts are reviewed by the representative no less than quarterly. Clients may request other reviews as the personal circumstances dictate. We ask that you immediately contact us if any material changes occur in your personal financial situation, such as a loss of a job, illness, inheritance, or any other factor that could materially change your investment objectives and/or risk tolerance. Fulcrum sends quarterly performance reports to all clients. Your independent qualified account custodian (Schwab) prepares and distributes account statements directly to you on no less than a quarterly basis. These account statements describe all activity in the clients’ accounts including account holdings, transactions, and investment advisory fees deducted from the account. The reports Fulcrum sends are not intended as a substitute for the custodial statements. We urge you to carefully compare the reports we send you with the statements sent from your custodian and to notify us promptly of any discrepancies. Item 14 - Client Referrals and Other Compensation As noted in the Other Financial Industry Activities and Affiliations section above, Fulcrum’s representatives receive compensation from their affiliation as a registered representative with Cetera, as well as through other income producing activities as described in the Other Financial Industry Activities and Affiliations section above, and in the representative’s ADV 2B Brochure Supplement. We neither pay anyone outside of the firm for referring clients to us, nor do we receive fees from other firms or individuals for referring clients to them. Item 15 - Custody Fulcrum does not maintain custody of our client funds or securities. Custody of client funds and securities is maintained by the custodian or clearing firm selected by you. The only exception to this is our ability to electronically deduct advisory fees with your express permission granted in the Advisory Agreement. It is important for you carefully review and compare the statement from the custodian to the invoices you receive from Fulcrum. Your custodian will send you, at least quarterly, a statement showing all transactions occurring in the account during the period covered by the account statement and the funds, securities, and other property in the account at the end of the period. Fulcrum and the representative will rely on the custodian to present values based upon information provided by the issuer of that security or other nationally recognized source as reported by the custodian. Fulcrum also provides other reports on the holdings and performance of the assets in the accounts. The valuation of the accounts in the reports provided by Fulcrum may differ slightly from the amount shown on the statement from the custodian. This potential difference stems from settlement date versus trade date accounting. It is important for the client to rely on the statement provided 14  by the Custodian for an accurate picture of the total assets in their accounts. Item 16 - Investment Discretion Our clients’ accounts are be managed on a discretionary basis. This authority is granted through a limited power of attorney in our advisory agreements. Discretionary authority permits Fulcrum to buy and sell securities in your account without obtaining prior consent to the transactions. We permit clients to place restrictions on our discretionary authority as long as we think those restrictions are operationally reasonable to implement and consistent with our fiduciary duty. Restrictions must be identified in writing and agreed to by Fulcrum. Item 17 - Voting Client Securities (Proxy Voting) Fulcrum does not have voting authority nor will give any advice for proxy voting for client securities. Item 18 - Financial Information We are not aware of any circumstance that is reasonably likely to impair our ability to meet contractual commitments to you or our other clients. We do not require pre-payment of investment advisory fees of $500 or more and six months or more in advance. Fulcrum Wealth Advisors - Privacy Policy Your privacy is a top priority for Fulcrum Wealth Advisors (“we” or “ us”). We take our commitment to protecting the confidentiality of your non-public personal information seriously. Financial service providers choose how they share your information, and federal law gives customers the right to limit some, but not all, sharing. Our Privacy Policy tells you how we collect, share and protect your information and provides you with an opportunity to opt out of sharing in certain circumstances as described below. Information That We Collect We collect personal information about you from a variety of sources to help us serve your financial needs, offer products and services and satisfy our legal and regulatory requirements. • We receive information provided by you or on your behalf, to us, or to our registered representatives, agents or financial professionals (financial professionals). This information may be provided on forms and applications as well as through personal discussions. For example, this information may include: social security number, name, address, birth date, assets, income, beneficiary, employment, health and other financial information. • We acquire information regarding your account and transaction history, including products and services, balances and payment history, and information as to your credit worthiness and history from our affiliates, unaffiliated service companies and consumer reporting agencies. • We receive information from other unaffiliated third parties, including employers, associations, benefit plan sponsors, financial aggregators and other institutions and individuals, including from institutions where you have had a relationship. Information We May Disclose We do not sell or disclose your non-public personal information to non-affiliated third-party marketing companies. We may disclose information that we collect as required to conduct our business and as permitted or required by law. We may share information about you with unaffiliated financial institutions such as our clearing firm, broker-dealers, investment advisors, third-party administrators, plan sponsors, mutual funds, insurance companies or agencies, solicitors and other third parties who assist us in providing account or related services 15  to you. We share information with non-financial companies that provide services to us such as consumer reporting agencies and consulting firms. We may share your information with auditors, regulators, non- regulatory industry licensing/registration entities and law enforcement organizations, including in response to court orders, subpoenas or inquiries, or as permitted or required by law. You are not able to opt out of our sharing your information for the purposes described in this section. Data Safeguarding We have implemented security standards and processes as well as physical, electronic and procedural safeguards—including training and confidentiality agreements—designed to protect your information. Policy Relating to Former Customers If you decide to close your accounts with us, or become an inactive customer, our Privacy Policy will continue to apply to you. If you would like a copy of our current Privacy Policy, please feel free to contact us or visit our website. Changes to Our Privacy Policy If we change this policy materially, we will notify you at least 30 days before the changes go into effect. 16