GLOBAL TRUST WEALTH MANAGEMENT LLC

Global Trust Wealth Management, LLC 515 North Flagler Drive, Suite 1700 West Palm Beach, FL 33401 561-207-9696 561-835-0628 (Fax) www.globaltrustwealth.com th@globaltrustwealth.com 04/30/2025 FORM ADV PART 2A BROCHURE This brochure provides information about the qualifications and business practices of Global Trust Wealth Management, LLC. If you have any questions about the contents of this brochure, please contact us by telephone at 561 207 9696. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Global Trust Wealth Management, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Global Trust Wealth Management, LLC is . Global Trust Wealth Management, LLC is a Registered Investment Adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. i  Item 2: Material Changes Global Trust Wealth Management, LLC has the following material changes to report. Material changes relate to Global Trust Wealth Management, LLC’s policies, practices or conflicts of interests. • Updated Item 4 and 5 to reflect use of the Pontera platform to manage held away assets. ii  IARD/CRD No: 333458 SEC File No.: Global Trust Wealth Management, LLC Form ADV Part 2A Brochure Table of Contents Item 1: Cover Page .......................................................................................................................... i Item 2: Material Changes ............................................................................................................. ii Item 3: Table of Contents ............................................................................................................ iii Item 4: Advisory Business ..............................................................................................................1 Item 5: Fees and Compensation ....................................................................................................4 Item 6: Performance-Based Fees and Side-By-Side Management ..............................................6 Item 7: Types of Clients .................................................................................................................7 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss .........................................8 Item 9: Disciplinary Information................................................................................................ 12 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...................................................................................................... 17 Item 13: Review of Accounts....................................................................................................... 21 Item 14: Client Referrals and Other Compensation................................................................... 22 Item 15: Custody .......................................................................................................................... 23 Item 16: Investment Discretion ................................................................................................... 24 Item 17: Voting Client Securities ................................................................................................ 25 Item 18: Financial Information .................................................................................................. 26 iii  Item 4: Advisory Business Form ADV Part 2A, Item 4 Established in 2024, Global Trust Wealth Management, LLC (hereinafter, “GTWM”) provides investment management, tax planning, estate planning, and retirement planning for individuals, corporations, trusts, and other entities. GTWM is a fee-only firm, meaning that we do not get compensated by commissions for sale of financial products. By being a fee-only firm, GTWM is able to better align clients’ interests with its own. The Members of GTWM are the Holt Family Office Inc, (wholly owned by Edward T. Holt, Jr.), Ryan Shore & Shawn Teufel. Asset Management Services: GTWM provides asset management services to clients. The services include the following: a. Investor Profile – GTWM consults with the client to obtain detailed financial information and other pertinent data to determine the appropriate investment guidelines, risk tolerance, and other factors that will assist in ascertaining the suitability of the asset management account. b. Portfolio Management Selection – GTWM provides continuous asset management of clients’ funds. GTWM diversifies and manages each clients’ portfolio. Investments are determined based upon client’s goals, investment objectives, risk tolerance, net worth, net income, and other various suitability factors. GTWM manages the client’s accounts on an individualized basis. Further restrictions and guidelines imposed by clients affect the composition and performance of portfolios. For these reasons, performance of portfolios within the same investment objective may differ and clients should not expect that the performance of their portfolios will be identical with the average client of GTWM. c. Performance Evaluation and Monitoring Services – GTWM makes available performance measurement services to its clients. At a minimum, annual performance evaluation reports are available annually (or more frequently at the client’s discretion). The internal reports are intended to inform clients as to the performance of their investments for the selected period. d. Discretionary Authority – The client will grant GTWM discretionary authority to buy and sell securities. Held Away Assets GTWM provide an additional service for accounts not directly held in our custody, but where we do have discretion, and may leverage an Order Management System to implement tax-efficient asset location and opportunistic rebalancing strategies on behalf of the client. These are primarily 401(k) accounts, HSA’s, and other assets we do not custody. We regularly review the available investment options in these accounts, monitor them, and rebalance and implement our strategies in the same way we do other accounts, though using different tools as necessary. The Order Management System allows GTWM to manage client accounts on a discretionary basis 1  without having to obtain and maintain a client’s login credentials. Clients using the Order Management System will receive a link allowing them to connect their account(s) to the platform. Once a client account is connected to the Order Management System, GTWM will monitor and rebalance or reallocate investments in that account in the same way as it/we does for other (non-held away) accounts, though using different tools. When clients engage GTWM in this capacity, they are responsible to keep the Pontera platform link active, so that GTWM will be able to access and manage the respective account without delay. If GTWM determines that an Order Management System link has become inactive, GTWM will use its best efforts to notify the client to resolve the issue. As of February 14, 2025, GTWM was managing approximately $ 207,248,417 of clients’ assets, with approximately $ 200,272,882 managed on a discretionary basis, and approximately $ 6,975,535 on a non-discretionary basis. Retirement Plan Consulting: We provide retirement plan consulting services to employer plan sponsors on a one-time or ongoing basis. Generally, such retirement plan consulting services consist of assisting employer plan sponsors in establishing, monitoring and reviewing their company's participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising could include: investment options, plan structure and participant education. All retirement plan consulting services shall be in compliance with the applicable state law(s) regulating retirement plan consulting services. This applies to client accounts that are retirement plans or other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and we accept appointments to provide our services to such accounts, we acknowledge that we are a fiduciary within the meaning of §3(21) of ERISA (but only with respect to the provision of services described in the signed advisory agreement). Retirement Plan Asset Management: We provide retirement plan asset management services on an ongoing basis. Generally, such asset management services consist of selecting, monitoring, removing, and/or replacing the investment options under the Plan, consistent with the objectives, written guidelines and/or investment objectives set forth in the written investment policy statement (“IPS”) accepted and adopted by the client. As the needs of the plan sponsor dictate, areas of management could include: plan investment options, asset allocation, plan structure, and participant education. We emphasize continuous and regular account supervision. Once the appropriate plan investments have been determined, we review the plan investments at least annually and if necessary, replace investments based upon the plan sponsor’s objectives, written guidelines and/or investment objectives. All retirement plan asset management services shall follow the applicable state law(s) regulating retirement plan consulting services. This applies to client accounts that are retirement plans or other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, 2  as amended (“ERISA”). If the client accounts are part of the Plan, and we accept appointments to provide our services to such accounts, we acknowledge that we are a fiduciary within the meaning of §3(38) of ERISA (but only with respect to the provision of services described in the signed advisory agreement). Services in General: Our investment and consulting recommendations are not limited to any specific product or service offered by a broker dealer or insurance company and will primarily include advice regarding the following instruments: • Exchange traded funds (ETFs) • “No-load” or “load-waived” mutual funds • Stocks • Bonds • Private, illiquid real assets and income-oriented investments for the funds • Exchange-Traded Options • United States government securities On rare occasions, when appropriate, we also recommend investments in the following instruments: • Equity and corporate debt securities • Certificates of deposit We tailor all of our asset management and consulting recommendations to the individual needs of each client. All such recommendations are tailored based on information gathered through client questionnaires, electronic communications, telephone, in-person discussions and relevant fund document 3  Item 5: Fees and Compensation Form ADV Part 2A, Item 5 Asset Management Services: Annually, GTWM charges a management fee based on the amount of assets under management. The percentage charged will not exceed 1.50% of assets under management. Billings will be made quarterly either after services rendered or in advance, as agreed to by the client. The current maximum management fee schedule is below. Fees and account minimums for these services are negotiable based upon certain criteria (i.e. anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, negotiations with client, etc.). ASSETS UNDER MANAGEMENT ANNUAL MANAGEMENT FEE Up to $2,000,000 1.50% On the next $8,000,000 1.25 % Amounts in excess of $10,000,000 1.00 % Fees are generally directly debited on a pro rata basis from the client’s account or accounts. The fee payable for any held away account will be deducted directly from another client account unless the held away account custodian has provided a mechanism for the client to authorize GTWM to deduct our fee directly from the held away account. In the event that a client’s account has insufficient funds or GTWM and the client agree, the fees will be billed directly to the client. Retirement Plan Consulting and Asset Management Billings will be made quarterly either after services rendered or in advance, as agreed to by the client. The agreed upon fees will be withdrawn from the client’s custodian account. The fee paying arrangements will be detailed in the signed advisory agreement. The current maximum management fee schedule for retirement plans is below. ASSETS UNDER MANAGEMENT ANNUAL MANAGEMENT FEE Up to $5,000,000 1.50% Amounts in excess of $5,000,000 1 .00% Fees in General: The client may grant GTWM authority to receive payments directly from the client’s custodian account. The client shall grant limited authorization to GTWM to withdraw the contractually agreed upon fees from the account. The custodian of the account is advised in writing of the limitation on 4  GTWM’s access to the account. We group certain related client accounts for the purposes of determining the account size and/or annualized fee. Pre-existing advisory clients are subject to GTWM’s minimum account requirements and advisory fees in effect at the time the client entered into the advisory relationship. Additionally, under certain circumstances, advisory clients who had pre-existing advisory relationships with our investment adviser representatives that originated while the representatives were employed at other advisory firms will have their pre-existing fee arrangements honored. As a result, our firm’s minimum account requirements and advisory fees will differ among clients. Account Termination: The contract may be terminated by either party upon 30 days written notice. Upon termination, GTWM will charge the client a prorated fee as appropriate for the time in which the client received GTWM’s services. A refund will be provided without penalty if the client terminates the contract, in writing, within five (5) days of the contract being executed. Mutual Fund and ETF Fees and Expenses: All fees paid to our firm for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds and ETFs to their shareholders. These 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. A client could invest in a mutual fund or an ETF directly, without the services of our firm. In that case, the client would not receive the services provided by us which are designed, among other things, to assist the client in determining which mutual fund or funds or ETFs are most appropriate to each client's financial condition and objectives. Moreover, certain DFA mutual funds may not be available to clients directly. Accordingly, the client should review both the fees charged by the mutual funds and ETFs and the fees charged by us to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. Brokerage and Custodial Fees: In addition to advisory fees paid to our firm, clients will also be responsible for all transaction, brokerage, trade-away and custodial fees incurred as part of their account management. Please see Item 12 of this Brochure for important disclosures regarding our brokerage practices. Please note, that none of GTWM’s personnel accepts compensation for the sale of securities or any other investment products, including service fees from the sale of mutual funds. GTWM strives to be an independent advisor at all times and always puts the clients’ interests first. 5  Item 6: Performance-Based Fees and Side-By-Side Management Form ADV Part 2A, Item 6 1. GTWM does not charge performance-based fees. 6  Item 7: Types of Clients Form ADV Part 2A, Item 7 GTWM has individuals, trusts, corporations, profit sharing plans, defined contribution plans, and individual retirement accounts. GTWM has a minimum family of accounts value of $500,000 which may be waived by the investment advisor. 7  Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Form ADV Part 2A, Item 8 Our Investment Philosophy: GTWM offers a program of managing assets on a discretionary basis for suitable clients, and on occasions GTWM will hold non-discretionary accounts. GTWM individualizes each client’s account to his or her particular needs/goals. After an extensive interview to determine what the client’s needs/goals are for his or her account, GTWM will prepare an Investment Policy Statement (“IPS”) targeting the amount of equities (broken down between large capitalization, small capitalization, international, and emerging markets), fixed income (broken down between core and high yield), commodities, and real estate that the account will maintain. GTWM believes that asset class selection plays a large part in determining expected returns. On the fixed income side, GTWM tends to favor short-term to intermediate-term bonds, high quality bonds and low duration holdings. In most instances, GTWM does not believe going out long on the maturities of bonds is beneficial to clients. The increase in risk does not generate a large enough increase in expected returns to compensate for this. GTWM chooses to minimize risk whenever possible through adequate diversification. Client accounts will contain a wide array of equities and fixed income securities to achieve this diversification. Furthermore, GTWM strives to invest in a multitude of global markets. By investing in a multitude of global markets, risk is minimized as clients’ accounts are not correlated strictly with one country’s economy. Although our clients’ accounts are well diversified, GTWM recognizes that clients’ accounts still can have a risk of loss when faced with poor market performance. GTWM’s clients should be prepared to bear a loss if poor market conditions exist. GTWM strives to minimize all losses in client accounts during such conditions. GTWM further believes that the costs of investing also have a large impact on clients’ returns. As such, GTWM is very cost conscientious when selecting investments for our clients. GTWM favors mutual funds with very low expense ratios, no loads, and no 12b-1 fees. Methods of Analysis: Mutual fund and/or ETF analysis: We look at the experience and track record of the manager of the mutual fund or ETF, the company, and the fund strategy in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We also look at the underlying assets in a mutual fund or ETF in an attempt to determine if there is significant overlap in the underlying investments held in other funds in the client’s portfolio. We also monitor the funds or ETFs in an attempt to determine if they are continuing to follow their stated investment strategy and how they measure up to their competitors. Asset allocation fund strategy and process are very important roles of analysis used at GTWM. In many cases this provides a much clearer picture than manager tracking. 8  A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not guarantee future results. A manager or fund strategy which has been successful may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a mutual fund or ETF, managers of different funds held by the client may purchase the same security, increasing the risk to the client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the mutual fund or ETF, which could make the mutual fund or ETF less suitable for the client’s portfolio. Fundamental Analysis: Fundamental analysis of a business involves reviewing its income statement, financial statements and health, its management and competitive advantages, and its competitors and markets. Fundamental analysts’ school of thought maintains that markets may misprice a security in the short run but that the "correct" price will eventually be reached. Profits can be made by trading the mispriced security and then waiting for the market to recognize its "mistake" and re-price the security. However, fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Therefore, unforeseen market conditions and/or company developments may result in significant price fluctuations that can lead to investor losses. Technical Analysis: Technical analysis seeks to identify price patterns and trends in financial markets and attempts to exploit those patterns. We follow and examine such indicators as price, volume, moving averages of the price and market sentiment. Charting: In this type of technical analysis, we review charts of market and security activity in an attempt to identify when the market is moving up or down and to predict how long the trend may last and when that trend might reverse. Since technical analysis predictions are only extrapolations from historical price patterns, investors bear risk that these patterns will not reoccur as expected. Moreover, technical analysis does not consider the underlying financial condition of a company. This presents a risk in that a poorly-managed or financially unsound company may underperform regardless of market movement. Cyclical Analysis: In this type of technical analysis, we measure the movements of a particular stock against the overall market in an attempt to predict the price movement of the security. Since cyclical analysis is based on examination of rising and falling trends, investors bear risk of mis-timing, with a specific trend lasting longer or shorter than expected. Risks for all forms of analysis: Our securities analysis method relies on the assumption that the companies whose securities we purchase and sell, the rating agencies that review these securities, and other publicly-available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. Our Investment Strategies: 9  Market Efficiency - One of GTWM’s core beliefs is that markets are efficient and work. Does this mean that all markets are perfectly efficient and all companies are correctly priced? No, it does not, but it does indicate that markets and company prices are a function of the public information available at any given time. GTWM Diversification, asset allocation, and cost are our most easily controlled allies, and are essential to define true investing. Asset Allocation - The client’s suitability and tolerance for risk drive our asset allocation strategy. Note there is no single optimal asset allocation because all clients are different and have different needs. Diversification - Diversification enables us at GTWM to capture broad market returns while reducing uncompensated risks that arise out of individual holdings. Success in this area is defined by not only capturing risks that generate return, but by reducing those risks that do not. Low Cost - At GTWM, we are a very cost conscious on all our investment decisions. Because of this, we are able to provide a much better return for our clients. Costs at all levels will negatively affect portfolio returns. The best way to attack cost is to reduce the costs internally generated through products. Here, we focus on fund expense ratios, attempting to provide the lowest possible expense ratios without sacrificing the fund’s quality. We also attempt to eliminate other fund costs that we believe add zero value to our client, such as loads and 12b-1 fees. Beta plus portable Alpha Strategy: GTWM may use a beta plus portable alpha strategy when managing client accounts. The beta component of this strategy is made up of mutual funds and ETFs and is intended to capture broad market conditions. The portable alpha component of these portfolios is mainly made up of individual stocks. These individual stock holdings are selected based on technical and fundamental analysis of the underlying companies researched. Alpha components are chosen based on the belief that they will outperform the broader market. The outperformance of this segment of the portfolio will help the overall portfolio achieve returns that are greater than those of the broad market. The risks of this investment strategy include separate Fundamental, Technical and Mutual Fund/ETF risks disclosed above. Long-term purchases: Our advice is mostly based upon long-term investment strategies. Therefore, we generally purchase securities with the idea of holding them in the clients account for a year or longer. We may do this because we want exposure to a particular asset class over time, regardless of the current projection for this class. A risk in a long-term purchase strategy is that, by holding the security for this length of time, we may not take advantages of short-term trading gains that could be profitable to a client. Our individual equities are meant to be high quality companies that offer long term opportunity for holding an asset that will produce ROE for the long term. Short-term purchases: Infrequently, we may also purchase securities with the idea of selling them within a relatively short time (typically a year or less). We do this in an attempt to take advantage of conditions that we believe will soon result in price increases through asset class positioning. 10  A risk in a short-term purchase strategy is that, should the anticipated price swing not materialize, we are left with the option of having a long-term investment in a security that was designed to be a short- term purchase, or potentially taking a loss. In addition, this strategy involves more frequent trading than does a longer-term strategy, and will result in increased brokerage and other transaction-related costs, as well as less favorable tax treatment of short-term capital gains. Clients should understand that investing in any securities, including mutual funds and ETFs, involves a risk of loss of both income and principal that a client should be prepared to bear. Margin transactions: We may purchase stocks for your portfolio with money borrowed from 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. A risk in margin trading is that, in volatile markets, securities prices can fall very quickly. If the value of the securities in your account minus what you owe the broker falls below a certain level, the broker will issue a “margin call,” and you will be required to sell your position in the security purchased on margin or add more cash to the account. In some circumstances, you may lose more money than you originally invested. 11  Item 9: Disciplinary Information Form ADV Part 2A, Item 9 There have been no criminal or civil actions against GTWM or any of its personnel. Furthermore, neither GTWM nor any of its personnel has had any violations of investment-related statutes or regulations. 12  Item 10: Other Financial Industry Activities and Affiliations Form ADV Part 2A, Item 10 Edward Thomas Holt, Jr. is a Non Equity Partner at Nowlen, Holt & Miner, P.A. (hereinafter, “NHM”), a public accounting firm. In addition, Ryan Shore is an employee of NHM. When appropriate, our advisory clients are referred to NHM and vice versa. However, no referral fees of any kind will be paid for these referrals by either party. Our firm shares office space, support staff, and office supplies with NHM. These non-advisory activities also present a potential conflict of interest because these non-advisory activities may require a time commitment, thus limiting the amount of time these individuals can dedicate to management of advisory client accounts. Finally, the sharing of office space creates privacy and information security challenges that we must address and monitor on an ongoing basis. We have policies and procedures in place which our team understands and follows to avoid issues based on such challenges. We endeavor at all times to put the interest of our clients first as part of our fiduciary duty as a registered investment adviser and take the following steps to address this conflict: 1. We disclose to clients the existence of all material conflicts of interest, including the potential for our firm and its employees to earn compensation from advisory clients in addition to our advisory fees; 2. We disclose to clients that they are not obligated to purchase any additional services from our firm or its employees; 3. We do not pay or collect referral fees from any related persons or entities; 4. We collect, maintain and document accurate, complete and relevant client background information, including the client’s financial goals, objectives and risk tolerance; 5. Our management conducts regular reviews of each client account to verify that all recommendations made to a client are suitable to the client’s needs and circumstances; 6. We require that our employees seek prior approval of any outside employment activity so that we can ensure that any conflicts of interests in such activities are properly addressed; 7. We periodically monitor these outside employment activities to verify that any conflicts of interest continue to be properly addressed by our firm; 8. We educate our employees regarding the responsibilities of a fiduciary, including the need for having a reasonable and independent basis for the investment advice provided to clients; and 13  9. We have implemented appropriate privacy, information security, and investment information sharing safeguards (physical and electronic) to ensure that our clients’ confidential, non-public information and our investment methods, ideas, and trading information are properly protected. 14  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Form ADV Part 2A, Item 11 Global Trust Wealth Management, LLC has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Personal Securities Transactions, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. YOU HAVE A RIGHT TO SEE OUR CODE OF ETHICS. FOR A COPY OF THE CODE OF ETHICS, PLEASE ASK YOUR FINANCIAL ADVISOR AT ANY TIME. At times, our firm or individuals associated with our firm buy or sell securities identical to those recommended to or purchased for customers for their personal accounts. In addition, there are times when a related person(s) has an interest or position in a certain security(ies) which is also be recommended to a client. Since we almost exclusively transact in highly liquid and widely-available securities, any potential conflicts of interest resulting from cases of limited availability should be greatly reduced. To further mitigate these potential conflicts of interest and ensure the fulfillment of our fiduciary responsibilities, we have established the following restrictions: 1. No principal or employee of our firm may buy or sell securities for their personal portfolio(s) where their decision is substantially derived, in whole or in part, by reason of his or her employment unless the information is also available to the investing public on reasonable inquiry. No principal or employee of our firm may prefer his or her own interest to that of the advisory client; 2. It is the expressed policy of our firm that no person employed by us may purchase or sell any security prior to a transaction(s) being implemented for an advisory account, and therefore, preventing such employees from benefiting from transactions placed on behalf of advisory accounts; 3. In certain instances, we aggregate our employee trades with client transactions where possible and when compliant with our duty to seek best execution for our clients. In these instances, participating clients will receive an average share price and transaction costs will be shared equally and on a pro-rata basis. In the instances where there is a partial fill of a particular batched order, we will allocate all purchases pro-rata, with each account paying the average price. Our employee accounts will be included in the pro-rata allocation; 15  4. We maintain a list of all securities holdings for our firm and anyone associated with this advisory practice with access to advisory recommendations. These holdings are reviewed on a regular basis; 5. We emphasize the unrestricted right of the client to decline to implement any advice rendered; 6. All of our principals and employees must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices; and 7. Any individual not in observance of the above may be subject to disciplinary action or termination. 16  Item 12: Brokerage Practices Form ADV Part 2A, Item 12 Soft Dollars In selecting or recommending broker-dealers, we consider the value research and additional brokerage products and services a broker-dealer has provided or will provide to our clients and our firm. Receipt of these additional brokerage products and services are considered to have been paid for with "soft dollars." When client brokerage commissions (or markups or markdowns) are used for these brokerage products and services, they provide a benefit to our firm because we do not have to produce or pay for the same brokerage products and services, which creates a potential conflict of interest in directing your brokerage business. We have an incentive to select or recommend a broker-dealer based on our interest in receiving the research or other products or services, rather than on our clients’ interest in receiving most favorable execution. To mitigate this potential conflict, before placing orders with a particular broker-dealer, we determine that the commissions to be paid are reasonable in relation to the value of all the brokerage and research products and services provided by that broker-dealer. In some cases, the commissions charged by a particular broker for a particular transaction or set of transactions may or may not be greater than the amounts charged by another broker-dealer that did not provide research services or products. In addition, we have instituted certain procedures governing soft dollar relationships including preparation of a mandated reporting of soft dollar irregularities, annual evaluation of soft dollar relationships, and an annual review of this brochure to ensure adequate disclosures of conflicts of interest regarding our soft dollar relationships. Products and services we receive from broker-dealers includes proprietary and third-party research data and analyses, financial publications, recommendations, or other information about particular companies and industries (through research reports and otherwise), and other products or services (e.g., software and databases) that provide lawful and appropriate assistance to our firm in the performance of our investment decision-making responsibilities. Consistent with applicable rules, brokerage products and services consist primarily of computer services and software that permit our firm to effect securities transactions and perform functions incidental to transaction execution. We use such products and services in our general investment decision making. The products and services we receive from broker-dealers are used in servicing our clients' accounts. Our use of these products and services will not be limited to the accounts that paid commissions to the broker-dealer for such products and services. In addition, these soft dollar benefits are not always to your accounts proportionately to the soft dollar credits generated by different client accounts. As part of our fiduciary duty to you, we endeavor at all times to put your interests first. As an adviser, we have access to the institutional platform of your account custodian. As such, we will also have access to research products and services from your account custodian and/or other brokerage firm. These products are in addition to any benefits or research we pay for with soft dollars. Such 17  research products and services are provided to all investment advisers that utilize the institutional services platforms of these firms, and are not considered to be paid for with soft dollars. However, you should be aware that the commissions charged by a particular broker for a particular transaction or set of transactions may (or may not) be greater than the amounts another broker who did not provide research services or products might charge. Our use of soft dollars is in accordance with the requirements of Section 28(e) of the Securities Exchange Act of 1934. Section 28(e) provides a "safe harbor" for investment managers who use commissions or transaction fees paid by their advised accounts to obtain investment research services that provide lawful and appropriate assistance to the manager in performing investment decision- making responsibilities. As required by Section 28(e), we will make a good faith determination that the amount of commission or other fees paid is reasonable in relation to the value of the brokerage and research services provided. In making this determination, we typically consider not only the particular transaction or transactions, and not only the value of brokerage and research services and products to a particular client, but also the value of those services and products in our performance of our overall responsibilities to all of our clients. Directed Brokerage We do not request or accept the discretionary authority to determine the broker dealer to be used for client accounts. Clients must direct us as to the broker dealer to be used for all client securities transactions. In directing the use of a particular broker or dealer, it should be understood that we will not have authority to negotiate commissions among various brokers, and best execution may not be achieved, resulting in higher transaction costs for clients. We currently require our clients to direct our firm to use Fidelity Brokerage Services, LLC (hereinafter, “Fidelity”) and Charles Schwab (“Schwab”), unaffiliated FINRA-registered broker dealers for the implementation of all portfolio transactions. Not all advisers require their clients to direct brokerage. Our firm participates in the Fidelity Institutional Wealth Services Program (hereinafter, “FIWS”) sponsored by Fidelity. While there is no direct linkage between the investment advice given to clients and our firm’s participation in the FIWS program, we receive economic benefits which would not be received if we did not give investment advice to clients. These benefits include: A dedicated trading desk that services FIWS participants exclusively, a dedicated service group and an account services manager dedicated to our firm’s accounts, access to a real-time order matching system, ability to block client trades, electronic download of trades, balances and positions, access, for a fee, to an electronic interface with FIWS' software, duplicate and batched client statements, confirmations and year-end summaries, the ability to have advisory fees directly debited from clients’ custodian accounts (in accordance with federal and state requirements), availability of third-party research and technology, a quarterly newsletter, access to Fidelity mutual funds, access to WealthCentral (internet access to statements, confirmations and transfer of asset status), access to Account View (through which clients may access their account information over the internet via our website), access to numerous mutual fund families and mutual funds NOT affiliated with Fidelity, of which many have no transaction fee, ability to have loads waived for our clients who invest in certain Fidelity loaded funds, when certain conditions 18  are met and maintained and the ability to have custody fees waived (when negotiated by the adviser and allowed under certain circumstances). Our firm also participates in Schwab Advisor Services (hereinafter, “AS”) offered by Charles Schwab & Co., Inc. ("Schwab") a broker dealer and securities clearing firm. AS offers us various services, including brokerage services, custodial, a trading platform with order aggregation, options, and fee payment services among others. The benefits we receive through participation in the FIWS, and AS programs depend upon the amount of transactions directed to, or amount of assets custodied by Fidelity or Schwab. Participation in the FIWS and AS programs results in a potential conflict of interest for our firm, as the receipt of the above benefits creates an incentive for us to recommend Fidelity and/or Schwab. Nonetheless, we have reviewed the services of Fidelity and Schwab and recommend their services based on several factors. These factors include the professional services offered, commission rates, and the custodial platform provided to clients. While, based on our business model, we will not seek to exercise discretion to negotiate trades among various brokers on behalf of clients, we will, however, periodically attempt to negotiate lower commission rates for our clients with Fidelity and Schwab. If a client, when undertaking an advisory relationship with our firm, already has a pre-established relationship with a broker and instructs us to execute all transactions through that broker, it should be understood that under those circumstances, we will not have the authority to negotiate commissions, obtain volume discounts and best execution may not be achieved. In addition, under these circumstances a disparity in commission charges may exist between the commissions charged to other clients since our firm may not be able to aggregate orders to reduce transaction costs or the client may receive less favorable prices. We reserve the right to decline acceptance of any client account for which the client directs the use of a broker if we believe that this choice would hinder our fiduciary duty to the client and/or our ability to service the account. A retirement or ERISA plan client may direct all or part of portfolio transactions for its account through a specific broker or dealer in order to obtain goods or services on behalf of the plan. Such direction is permitted provided that the goods and services provided are reasonable expenses of the plan incurred in the ordinary course of its business for which it otherwise would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the plan. Trade Aggregation: If we determine that aggregation of trades in a certain situation will be beneficial to our clients, transactions will be averaged as to price and will be allocated among our clients in proportion to the purchase and sale orders placed from each client account on any given day. Any exceptions from the pro-rata allocation procedure will be carefully explained and documented. Such exceptions occur due to one or more of the following reasons: varying cash availability across accounts; divergent investment objectives and existing concentrations; tax considerations; investment restrictions; performance relative 19  to the applicable benchmark; performance relative to other accounts in the same strategy; and desire to avoid “odd lots,” (an amount of a security that is less than the normal unit of trading for that particular security). 20  Item 13: Review of Accounts Form ADV Part 2A, Item 13 Asset Management Services: The securities in every client's account will be under continuous review. Also, all separately managed accounts will be formally reviewed quarterly as agreed to by the client. The review process contains each of the following elements: A) assess client's goals and objectives; B) evaluate the strategy which has been employed; and C) monitor the portfolio. Account reviews typically are triggered by any one or more of the following events: A) significant changes in client's personal circumstances; B) significant changes in the general economy and/or tax law; C) quarterly; and D) changes in policy limits. All clients will receive an annual report outlining their current positions, security cost basis, and current market values. Clients also have available performance analysis reports which display the time rated returns realized in the clients' account. The types of reporting vary based on the clients' circumstances. All such reports will be in addition to monthly statements received by the client from the client's custodian. All clients in need of a more frequent report may request that additional service. Retirement Plan Consulting/ Retirement Plan Asset Management: Retirement plan consulting clients and retirement plan asset management clients, receive reviews of their plans for the duration of the plan consulting service. We also provide ongoing services to consulting clients where we meet with such clients upon their request to discuss updates to their plans, changes in their circumstances, etc. 21  Item 14: Client Referrals and Other Compensation Form ADV Part 2A, Item 14 GTWM does not compensate non-advisory personnel (solicitors/promoters) for client referrals. Should GTWM ever pay a referral fee, we require that the person provide the prospective client with a copy of this document and a separate disclosure statement that includes the following information: the person's name and relationship with our firm; the fact that the person is being paid a referral fee; the amount of the fee; and whether the fee paid to us by the client will be increased above our normal fees in order to compensate the person. 22  Item 15: Custody Form ADV Part 2A, Item 15 Third-Party Standing Letters of Authorization. Our firm and related persons of our firm have limited custody of certain of our clients’ assets based on standing letters of authorization with certain clients that grant our firm the authority to make certain asset transfers to third parties on behalf of those clients. Direct Debiting of Advisory Fees. We previously disclosed in the “Fees and Compensation” section (Item 5) of this Brochure that the client may grant our firm authority to receive payments directly from the client’s account. As part of this billing process, the client’s custodian is advised of the amount of the fee to be deducted from that client’s account. On at least a quarterly basis, the custodian is required to send to the client a statement showing all transactions within the account during the reporting period. Because the custodian does not calculate the amount of the fees to be deducted, we urge our clients to carefully review their custodial statements to verify the accuracy of the calculation, among other things. Clients should contact us directly if they believe that there may be an error in their statement. In addition to the periodic statements that clients receive directly from their custodians, we also send reports outlining their current positions, security cost basis, and current market values directly to our clients on an annual basis. We urge our clients to carefully compare the information provided on these statements to ensure that all account transactions, holdings and values are correct and current. 23  Item 16: Investment Discretion Form ADV Part 2A, Item 16 Global Trust Wealth Management, LLC generally only accepts client assets on a discretionary basis. However, this authority is limited to the investment ranges discussed in each client’s individualized Investment Policy Statement. Global Trust Wealth Management, LLC will not place any discretionary trades on a client’s account until we have agreed to an Investment Advisory Agreement and/or Investment Policy Statement with the client. Should the client wish to impose reasonable limitations on this discretionary authority, such limitations shall be included in this written authority statement. Clients may change/amend these limitations as desired. Such amendments must be submitted to us by the client in writing. 24  Item 17: Voting Client Securities Form ADV Part 2A, Item 17 As a matter of firm policy, we do not vote proxies on behalf of clients. Therefore, although our firm provides investment advisory services relative to client investment assets, clients maintain exclusive responsibility for: (1) directing the manner in which proxies solicited by issuers of securities beneficially owned by the client shall be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s investment assets. Clients are responsible for instructing each custodian of the assets to forward to the client copies of all proxies and shareholder communications relating to the client’s investment assets. We do, however, offer consulting assistance regarding proxy issues to clients if such assistance is sought by a client. We will neither advise nor act on behalf of the client in legal proceedings involving companies whose securities are held in the client’s account(s), including, but not limited to, the filing of “Proofs of Claim” in class action settlements. If desired, clients may direct us to transmit copies of class action notices to the client or a third party. Upon such direction, we will make commercially reasonable efforts to forward such notices in a timely manner. 25  Item 18: Financial Information Form ADV Part 2A, Item 18 As an advisory firm that maintains discretionary authority for client accounts, we are also required to disclose any financial condition that is reasonable likely to impair our ability to meet our contractual obligations. We have no such financial circumstances to report. Under no circumstances do we require or solicit payment of fees in excess of $1,200 per client more than six months in advance of services rendered. Therefore, we are not required to include a financial statement. We have not been the subject of a bankruptcy petition at any time during the past ten years. 26