Overview

Headquarters
El Dorado Hills, CA
Total Firm Assets
$238 million
Average High-Net-Worth Client Portfolio Size
$3.0 million
Stated Minimum Account Size
$1,000,000

Fee Disclosure

GOLDENSTONE WEALTH MANAGEMENT FIRM BROCHURE

MinMaxDisclosed Annual Rate
$0 $1,000,000 1.25%
$1,000,001 $3,000,000 1.00%
$3,000,001 $5,000,000 0.80%
$5,000,001 $10,000,000 0.65%
$10,000,001 $15,000,000 0.55%
$15,000,001 $20,000,000 0.50%
$20,000,001 and above 0.40%
Estimated Annual Fees (Based on ADV disclosures. Where a range is given, we use the upper rate)
Portfolio ValueEstimated Annual FeeEffective Fee Rate
$1 million $12,500 1.25%
$5 million $48,500 0.97%
$10 million $81,000 0.81%
$50 million $253,500 0.51%
$100 million $453,500 0.45%

Clients

High-Net-Worth Share of Firm Assets
70.12%
Number of High-Net-Worth Clients
55
Total Client Accounts
236
Discretionary Accounts
230
Non-Discretionary Accounts
6

Services Offered

Services: Portfolio Management for Individuals

Regulatory Filings

SEC CRD Number
310041

Primary Brochure: GOLDENSTONE WEALTH MANAGEMENT FIRM BROCHURE (2026-09-18)

View Document Text
Item 1: Cover Page for Part 2A of Form ADV: Firm Brochure Version date: September 2026 Goldenstone Wealth Management, LLC Firm CRD: (310041) Principal Office Address: 5170 Golden Foothill Parkway El Dorado Hills, CA 95762 Firm Contact: Sanjay Varshney, PhD, CFA Chief Compliance Officer Firm Website Address: www.goldenstonewealth.com please contact us by telephone at (916) 799-6527 This brochure provides information about the qualifications and business practices of Goldenstone Wealth Management, LLC. If you have any questions about the contents of this brochure, or contact@goldenstonewealth.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any State Securities Authority. Additional information about Goldenstone Wealth Management is available on the SEC’s website at www.adviserinfo.sec.gov. Please note that the use of the term “registered investment adviser” and description of Goldenstone Wealth Management, LLC and/or our advisors as “registered” does not imply a certain level of skill or training. You are encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise you for more information on the qualifications of our firm and our employees. ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement Goldenstone Wealth Management | Page 1 Item 2: Material Changes Goldenstone Wealth Management, LLC (“Goldenstone Wealth Management”) is required to advise you of any material changes to our Firm Brochure (“Brochure”) from any previous version or last update, discuss those changes on the cover page of our Brochure or on the page immediately following the cover page, or in a separate document accompanying our Brochure. We must state clearly that we are discussing only material changes since the last annual update of our Brochure, and we must provide the date of the last annual update of our Brochure. The material changes in this brochure from the last annual updating amendment of Goldenstone Wealth Management, LLC in February 2026 are described below. • No Material Changes to Report ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement Goldenstone Wealth Management | Page 2 Table of Contents Item 1: Cover Page for Part 2A of Form ADV: Firm Brochure .............................................................. 1 Item 2: Material Changes .................................................................................................................. 2 Item 4: Advisory Business .................................................................................................................. 4 Item 5: Fees & Compensation ............................................................................................................ 6 Item 6: Performance-Based Fees & Side-By-Side Management .......................................................... 7 Item 7: Types of Clients & Account Requirements ............................................................................... 7 Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ..................................................... 8 Item 9: Disciplinary Information ...................................................................................................... 11 Item 10: Other Financial Industry Activities & Affiliations ................................................................. 11 Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading ............. 12 Item 12: Brokerage Practices .......................................................................................................... 12 Item 13: Review of Accounts ........................................................................................................... 14 Item 14: Client Referrals & Other Compensation .............................................................................. 14 Item 15: Custody ............................................................................................................................. 16 Item 16: Investment Discretion ....................................................................................................... 17 Item 17: Voting Client Securities ...................................................................................................... 17 Item 18: Financial Information ........................................................................................................ 17 Part 2B of Form ADV Brochure Supplement Item 1: Cover Page ...................................................... 18 ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement Goldenstone Wealth Management | Page 3 Item 4: Advisory Business Goldenstone Wealth Management (the “Firm”, “we”, “us”, “Goldenstone”), is an independent investment management and advisory firm, founded in July, 2020. It is structured as a Limited Liability Company and is owned equally (50% each) by the two founders and partners that also serve as the only two advisers for the Firm: • Sanjay Varshney, PhD, CFA • Andres Villegas, CFA Goldenstone is not owned by any parent company and does not have any subsidiaries, intermediate or otherwise. Our Founders strive to help their clients succeed in meeting their financial goals. They have worked extensively in the Financial industry including on the institutional side of the business. We help clients through bull and bear markets, through economic booms and busts, and help them navigate difficult and uncertain financial times with discipline, skill, and confidence. Our collective wealth management experience spans over 50 years, having managed millions of dollars for clients in small investment boutiques as well those in one of the nation’s largest wealth management firms. Our advisors hold the Chartered Financial Analyst (CFA®) designation. We always act as your fiduciary. A fiduciary has the greatest legal duty to uphold themselves to the highest ethical standards and utmost integrity by putting client’s interests above their own personal interests. We manage your money using loyalty, prudence, and care. Per U.S. Department of Labor (“DOL”), Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”), all IRA assets, whether rollover or otherwise, will receive the same fiduciary treatment as all other assets. In no way, will clients’ interest ever be preceded by any other interest. Our Services are summarized below: Investment Management The portfolios, plans, and strategies we build are individualized and customized to your objectives, risk tolerance, time horizon, goals for cash flows and income, and other considerations affecting your wealth and portfolio needs, recognizing that you are unique and different. We serve individuals, business owners, and institutional clients. We serve as fiduciaries for our clients and honor their requests and any restrictions the clients may impose on investing in certain securities or types of securities. We do not participate in wrap fee programs. ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement Goldenstone Wealth Management | Page 4 As of December 2025, Goldenstone Wealth Management has: Discretionary assets: Non-discretionary asset: Total assets: $177,341,000 $60,918,000 $238,259,000 230 6 236 • Ongoing Portfolio/Asset Management, Monitoring, Trading, and Rebalancing • Customized Income and Growth Strategies • Goals-Based Investing • Tax Mitigation Strategies • Portfolio Analysis and Strategies • Economic, Market Updates, and Reviews • Interpretation of the Global Economic and Financial Markets Retirement Planning Whether you’re retired, thinking about early retirement, or need a second opinion, we can help you properly plan, adapt, and aim for a successful retirement journey. We help you reach your retirement goals. Individual Retirement Accounts (IRAs) • • 401(k) Rollovers • SEP IRAs • Solo 401(k), Individual 401(k), Owner-Only 401(k) • SIMPLE IRAs • Profit Sharing Plans • Retirement Income Strategies • Understand your Balance Sheet • Grow your Net Worth Financial Planning We conduct a free comprehensive evaluation of your current and future income sources, savings, and investments to formulate an investment strategy specific to saving, investing, and planning. This is part of our holistic discovery and evaluation process to provide the best portfolio management services. • Investment Planning • Retirement Planning • Cash Flow Planning • Education Planning • Philanthropic Planning ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement Goldenstone Wealth Management | Page 5 Item 5: Fees & Compensation The fee of the Adviser shall be calculated on the basis of the total market value of the assets placed under supervision, and is billed quarterly at the end of each calendar quarter (March 31, June 30, September 30, December 31). It shall be calculated on the basis of the total market value of such assets as of the close of business on these quarter end dates. Fees are deducted directly from the client account. If assets are placed under supervision within two weeks of a quarterly end date, no advance fees are charged, and the first billing is charged to the subsequent quarter. If the advisory relationship with Goldenstone begins more than two weeks from a quarter end date, then Goldenstone will charge fees for that quarter pro-rated for only the days of actual advisory service from account inception to the quarter end date. At no time will the client ever pay any fees in advance. Should the client terminate the relationship prior to a quarter end date, Goldenstone will bill the client on a pro-rated basis only for those days in the quarter of advisory services up until the date of termination. There are no fees for financial planning or retirement planning services and we conduct a complimentary comprehensive evaluation to our clients as part of our holistic investment management process. We conduct a free comprehensive evaluation of your current and future income sources, savings, and investments to formulate an investment strategy specific to saving, investing, and planning. The Fee Schedule below is implemented for any clients onboarded after March 1, 2025. In no way will any of our existing clients be impacted by this fee schedule so long as they remain clients of ours. While the new fee schedule is being implemented for any new clients, once again we may provide discounts on a case-by-case basis. Clients are advised that lower fees for comparable services may be available from other sources. Such fee shall be calculated at the following annual blended rates and payable quarterly: DISCRETIONARY MANAGED ACCOUNT 1.25% of assets under management for assets under 1.00% of assets under management between 0.80% of assets under management between 0.65% of assets under management between 0.55% of assets under management between 0.50% of assets under management between 0.40% of assets under management above $1 Million $1-3 Million $3-5 Million $5-10 Million $10-15 Million $15-20 Million $20 Million PRIVATE CAPITAL AND ALTERNATIVE INVESTMENTS Additional annual management fee ranging from 0.50%-1.50% of the specific assets under management (Private Credit: up to 0.50%, Other Private Capital: up to 1.00%, Co-Investments: up to 1.50%) ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement Goldenstone Wealth Management | Page 6 OPTION STRATEGIES Additional annual fee of 1.00% of the covered assets/option strategy under management 401K CORPORATE RETIREMENT ASSETS (Business Corporate 401k Plans Only) 0.5% of plan assets under management RECOMMENDED ACCOUNT MINIMUM $1,000,000 We do not: • receive any brokerage commissions or custodial fees • sell insurance • participate in underwritings • participate in wrap fee programs • receive any fees from tax shelter programs, mutual funds, or any products which might cause a potential conflict of interest. • receive any fees from the sale of any securities or investment products We are a fee-only advisor and will always serve you with the utmost integrity by acting as your fiduciary at all times. While we will adhere to the schedule of fees described above at all times, there may be occasional cases where we may be willing to negotiate a lower fee on a need and case by case basis. We recommend Charles Schwab for custody of client assets. Clients will incur brokerage and other transaction costs (such as mutual fund expenses, private capital expenses, options trading and management expenses, block trade allocation expenses) that are specific to the custodian where the assets are held or the manager/sub-manager for the investment strategy employed. Please be advised of the section(s) of our brochure that discusses brokerage for more details. To the extent possible Goldenstone will minimize the expenses to the client through use of low expense ratio ETFs, no load funds and other investment strategies that can produce comparable returns with similar risk. Item 6: Performance-Based Fees & Side-By-Side Management We do NOT charge performance-based fees. We also do not charge any other type of fee such as an hourly or flat fee, or any asset based or asset specific fee. Item 7: Types of Clients & Account Requirements We expect to have the following types of clients: • • Individuals and High Net Worth Individuals; Institutional Clients; ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement Goldenstone Wealth Management | Page 7 • Trusts, Estates or Charitable Organizations; • Profit Sharing and Retirement Plans; • Corporations, Limited Liability Companies and/or Other Business Types Our requirements for opening accounts or otherwise engaging us: • We generally require a minimum household balance of $1,000,000. Item 8: Methods of Analysis, Investment Strategies & Risk of Loss As a Wealth Management Firm, we help support your financial goals as you strive to grow and/or preserve capital. There are several dimensions that are important in the portfolio management process such as understanding the fundamental and technical factors influencing markets, historical trends, business and economic cycles, monetary and fiscal policies, risk (political, economic, company specific, regulatory, market) and their impact on security prices and consequently your portfolio. Clients are advised that fundamental and technical trends from the past may not be true for the future. While reasonable assumptions can be made about past business cycles, and the impact of monetary and fiscal policy on markets and securities, the past may not be a predictor of the future. We assume a long-term horizon for investment decision-making and consider your ability and willingness to take risk. We employ a series of disciplines – qualitative and quantitative, utilizing comprehensive fundamental, technical, and economic analyses. We do not pursue any extraordinary strategies that may involve significant or unusual risks outside of market risks, such as frequent trading of securities that usually can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. We pursue strategies to analyze markets from top-down and bottom-up perspectives. Our investment programs are designed to meet your objectives within realistic limits of capital markets using traditional asset classes of stocks, bonds, and real assets that are mostly liquid and traded in the public securities markets. On occasion, for accredited investors or qualified purchasers, we may consider based on risk tolerance, time horizon, and return goals some alternative assets such as private capital and hedge funds. However, these alternative assets are not for everyone since they come with substantially more risk, and are not that liquid, compared to marketable securities such as stocks and bonds. As fiduciaries, we may on occasion determine, based on client suitability and under full advisement with the client, option strategies limited to collars, covered calls and protective puts to generate income and/or minimize risk in the client’s portfolio. Such strategies would be pursued only if appropriate based on our macro analysis of the economy and the markets, client’s personal situation as well as risk profile, and only if appropriate and beneficial for the client’s portfolio. Covered call writing is the sale of in-, at-, or out-of- the money call option against a long security position held in a client portfolio. This type of transaction is used to generate income. It ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement Goldenstone Wealth Management | Page 8 also serves to create downside protection in the event the security position declines in value. Income is received from the proceeds of the option sale. Such income may be reduced to the extent it is necessary to buy back the option position prior to its expiration. This strategy may involve a degree of trading velocity, transaction costs and significant losses and/or tax implications if the underlying security has volatile price movement. Covered call strategies are generally suited for companies with little price volatility. Protective puts provide protection against market downturns or in the event of specific decline in the stock or the market price. Buying puts require a premium against the stock or the market in the form an insurance policy, which may or may not get utilized. In the event the put is not exercised the premium is lost, however, the premium serves its purpose as insurance against downside movement in the underlying security. An Options Collar is an options strategy used primarily to protect an existing stock position from a significant decline while giving up some upside potential. A typical collar involves three positions: Own the underlying stock (or ETF). Buy a protective put — gives you the right to sell the stock at a predetermined strike price, limiting downside below that level. Sell a covered call — gives someone else the right to buy your stock at a predetermined strike price, limiting your upside above that level. The premium received from selling the call can partially or fully offset the cost of buying the put. The benefits include downside protection by establishing a floor on potential losses; reduced hedging cost: The call premium can help pay for the put; defined risk/reward: You know approximately where your downside protection and upside cap are; useful for concentrated holdings: Can help protect an appreciated stock position without immediately selling it. Key risks / disadvantages of a collar are: Upside is capped: A strong rise in the stock may result in the shares being called away. Protection isn't free: If the call premium doesn't fully cover the put premium, you pay a net cost. Limited flexibility: The strategy can restrict your ability to benefit from large price increases. Assignment risk: The short call can be exercised, particularly around expiration or when it is deep in-the-money. Expiration/roll risk: You may need to roll the options to maintain protection, potentially at an unfavorable cost. In short: A collar is essentially a trade-off: you sacrifice some upside potential in exchange for meaningful downside protection, often at a relatively low net cost. As we use fundamental and technical analysis to understand market trends and pricing in the stock market, we shall utilize either the covered call to generate additional income or the protective put to avoid losses as appropriate only if previously agreed upon with the client. We pursue an active global multi-asset total return policy to maximize portfolio returns through a combination of asset allocation, asset mix, equity style selection, and security selection. These are carefully and effectively custom tailored to your individual needs and constraints along with strategic investment tactics. We start by listening and engaging in meaningful conversations with you. Then, we provide personalized advice to help you reach and manage your goals. Our personalized advice includes many dimensions, but primarily revolves around building a proper investment program designed to meet your cash flow needs, follow your risk appetite, grow over your time horizon, and be tax and cost efficient. In addition to managing money, we manage relationships. We recognize the need for our clients to consult with us any time they wish at their convenience, or to discuss with us life changes that could change the portfolio strategy. We are passionate and driven to exceed client expectations. ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement Goldenstone Wealth Management | Page 9 Our goal is to help you succeed financially through: • Long-term investing and disciplined strategy • Minimizing broad market risk from portfolios • Pursuing active strategies • Understanding market trends from countries and industries • Portfolio management • Keeping perspectives of business cycles • Removing emotion from decision-making process • Interpreting impact of monetary and fiscal policy Important Risk Considerations: Investing in securities involves possible risk of principal that clients should be prepared to bear. It is possible for your investments to increase or decrease in value with fluctuations of the stock market, therefore you should be prepared to bear the risk associated with investing in the stock market. It is important that you understand the risks associated with investing in the stock market, are appropriately diversified in your investments, and consult with us to answer your questions. Investment strategies and market investments involve risk arising from a variety of factors such as: interest rate risk, market risk, inflation risk, currency risk, reinvestment risk, business risk, liquidity risk, economic risk and general financial risk. These risks can impact security prices, portfolio valuations, and may result in loss. Not all investments are suitable for all clients. Certain investments may only be appropriate for those who have higher risk tolerance, higher net worth disposition, or higher income. Option strategies are among investments that may not be suitable for all clients. As fiduciaries, we may on occasion determine, based on client suitability and under full advisement with the client, option strategies limited to collars, covered calls and protective puts to generate income and/or minimize risk in the client’s portfolio. While covered calls and protective puts reduce risk somewhat, they cannot eliminate it entirely. Covered calls usually prevent significant profit potential if a stock moves substantially in your favor. Anytime you sell a covered call, you have established a maximum selling price (covered call) for your stock. Any stock movement beyond that established price creates no additional profit for you and you could give up any gains or appreciation beyond that. Losses are reduced only by the amount of premium received on the initial sale of the covered call. While it is possible to hold the options until expiration, you can usually close out a covered option at any time by buying it to close at the current market price. A significant change in the price of the underlying stock prior to expiration could result in an early assignment, and if your short option is in-the-money, you could be assigned at any time, consequently triggering a sale of your position and/or potentially generating capital gains. Covered calls written against dividend paying stocks are especially vulnerable to early assignment. Protective puts carry risk in the event markets or the stock does not go down and the premium paid on the protected put is lost. Premiums received from the sale of covered calls or premiums paid from the purchase of protective puts are determined on factors including but ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement Goldenstone Wealth Management | Page 10 not limited to: current market volatility, volatility of the underlying security, interest rates in the market, time of the contract, dividends of the underlying security, macroeconomic and market factors, or reasons specific to the underlying security. Investments in private capital such as private equity, private real estate, private debt, or hedge funds, could have substantial illiquidity risk, concentration risk, and should be used only for accredited investors as defined by the Securities Exchange Commission (SEC). Additional considerations and paperwork will be required of clients wanting to invest in any private capital opportunities. Clients are advised to consult their legal and tax advisors, in addition, to consulting us prior to making any investment in private capital. Item 9: Disciplinary Information There are no legal or disciplinary events that are material or non-material involving Goldenstone or any of its founders/advisers that may impact or affect a client’s or prospective client’s evaluation of our advisory business or the integrity of our management. Item 10: Other Financial Industry Activities & Affiliations Our firm has NO other Financial Industry activity, affiliation with any other firm, ownership in, or owned by any other firm. We have no conflict of interest arising as a result. Goldenstone has only two employees/advisers – both are partners and founders, and both hold the CFA designation. We are not registered or propose to register as a broker-dealer, a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. We have no relationship that would cause conflict of interest for our clients or any arrangement with entities such as broker-dealer, municipal securities dealer, or government securities dealer or broker, investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or “hedge fund,” and offshore fund), other investment adviser or financial planner, futures commission merchant, commodity pool operator, or commodity trading advisor, banking or thrift institution, accountant or accounting firm, lawyer or law firm, insurance company or agency, pension consultant, real estate broker or dealer, sponsor or syndicator of limited partnerships. We do NOT recommend or select other investment advisers for our clients or receive compensation directly or indirectly from those advisers that creates a material conflict of interest, or have other business relationships with those advisers that create a material conflict of interest. ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement Goldenstone Wealth Management | Page 11 Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading Goldenstone is committed to applying a high Code of Ethics and require that all such transactions be carried out in a way that does not endanger the interest of any client. At the same time, we believe that if investment goals are similar for clients and for the advisers, it is reasonable and even desirable that there may be common ownership of some securities. We are a fee-only advisory firm. We are independent and have no conflicts of interest or affiliations with marketing groups. Goldenstone is operated and managed by the Owners and Founders. As a fiduciary, it is our responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our clients at all times. Our fiduciary duty is considered the core principle for our Code of Ethics which also includes Insider Trading and Personal Securities Transactions Policies and Procedures. We require ourselves (both founders/advisers) to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws at all times. We both will sign an acknowledgement that we have read, understand, and agree to comply with our Code of Ethics. This acknowledgement will be shared at the request of the client. Our firm and supervised persons must conduct business in an honest, ethical, and fair manner at all times and avoid all circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure is provided to give all clients a summary of our Code of Ethics. Related persons of our firm (both founders/advisers) will buy or sell some securities and other investments that are also recommended to clients. This presents a conflict of interest regarding the prices paid or received for client transactions vis-à-vis those of the Firm’s advisors or related persons. Our Code of Ethics outlines the process for quarterly reviews of all Firm personnel/advisor/related person transactions to ensure that clients are not adversely impacted by personal trades. A copy of our Code of Ethics will be provided to any client or prospective client upon request. Item 12: Brokerage Practices We seek to recommend a custodian/broker who will hold your assets and execute transactions on terms that are overall most advantageous when compared to other available providers and their services. We consider a wide range of factors, including, among others, these: • Confidentiality of trading activity and adviser/client relationship • Timeliness of execution and best price execution • Frequent and timely trade confirmations • Liquidity of the securities traded and access across markets • Ability to place trades in difficult market environments • Ability to execute and custody private capital ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement Goldenstone Wealth Management | Page 12 • Research services and trading tools provided • Client interface tools and ease of use by clients • Custody services provided and quality of services • Financial condition and safety of assets • Business reputation and reliability of services Goldenstone had at inception entered into an agreement to use TD Ameritrade Inc. (TD Ameritrade) as the primary custodian and trading platform for our clients (“custodian”). TD Ameritrade, Inc. was acquired by Charles Schwab & Co. Charles Schwab is an independent and unaffiliated SEC-registered broker-dealer. Charles Schwab offers to independent investment Advisors services which include custody of securities, trade execution, clearance and settlement of transactions. Charles Schwab offers zero commission trades. They charge brokerage commissions and transaction fees for certain securities transactions (i.e., transaction fees are charged for certain no-load mutual funds, expenses and costs related to options transactions, commissions are charged for debt securities transactions, there may be charges associated with custody of private capital assets). They provide access to many no-load mutual funds without transaction charges and other no-load funds at nominal transaction charges. However, the commission and transaction fees charged by our custodian may be higher or lower than those charged by other custodians and broker-dealers. Charles Schwab provides comprehensive custodian services to include at no charge to us or the client: • Company/Industry research products/reports • Economic reports, data and analyses • Financial publications and news • Pricing data and portfolio evaluation services Goldenstone does not receive any part of, or use client brokerage commissions to obtain research or other products or services. Research and brokerage services at Charles Schwab are used by our firm to manage those accounts of our clients custodied there. Since we do not have to pay to produce or pay for such research, this has the potential to pose a conflict of interest while recommending Charles Schwab as the custodian, including not receiving the best execution had we selected another firm for custody that could provide better execution on a specific trade or transaction. We look to Charles Schwab to provide us the most favorable execution, and the most efficient custody of clients’ assets. Goldenstone also utilizes research from other sources and does not depend solely on such products/services from Charles Schwab. Neither Goldenstone Wealth Management nor its Founders/Advisors receive research (other than research available to clients for using Charles Schwab platform) or other products or services other than execution from a broker-dealer or a third party (“soft dollar benefits”) in connection with client securities transactions. Goldenstone investigated any potential conflict of interest and concluded that using them as our ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement Goldenstone Wealth Management | Page 13 primary custodian serves the best interests of our clients and satisfies our fiduciary obligations, including our duty to seek best execution. Goldenstone does not receive brokerage commissions or client referrals from the recommendation of Charles Schwab as custodian. We do not have discretionary authority in making the determination of the brokers with whom orders for the purchase or sale of securities are placed for execution, and the commission rates at which such securities transactions are effected. Goldenstone does not require client- directed brokerage to any specific broker-dealer, but recommends Charles Schwab as discussed earlier. Client-Directed Brokerage Arrangement refers to an arrangement whereby a Client directs that trades for its account be executed through a specific Broker in exchange for which the Client receives a benefit in addition to execution services. If a client insists on or requires using a specific custodian of their choice, or direct brokerage, the client is advised that we may be unable to achieve most favorable execution of client transactions. Directing brokerage may cost clients more money. Goldenstone proposes to use aggregation only if it does not result in any additional costs to clients, and serves to be both expedient and efficient from a best execution standpoint. Item 13: Review of Accounts We review accounts on at least a quarterly basis for all of our clients. We continuously monitor all client portfolios and assets, and review them to ensure that our clients’ accounts are aligned with their investment objectives, risk tolerance, investment horizon, and investment policies as applicable. We will rebalance portfolios as needed to reflect current market conditions, and ensure that the portfolios and assets are managed with prudence and care, since we are fiduciaries. All reviews will be conducted only by the firm’s founders/advisers. We will meet with our clients upon their request, on at least an annual basis, or per agreed schedule, to discuss updates to their plans, changes in their circumstances or other questions or concerns they may have. We may review client accounts and/or meet with clients more frequently, if such reviews or meetings are triggered due to major or unusual changes in markets, the economy, the client’s personal circumstances or life events, or requests by the client, etc. We provide written reports to clients on at least an annual basis, and quarterly for those clients who want those. Clients will also receive reports from their custodian, monthly, or quarterly at the least, and have full access to their accounts and records online. All reviews will be conducted by: Sanjay Varshney, Principal/Adviser, and/or Andres Villegas, Principal/Adviser. Item 14: Client Referrals & Other Compensation As part of our fiduciary duties to our clients, we endeavor at all times to put the interests of our clients first. We do not receive any economic benefit or fee from anybody other than the client ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement Goldenstone Wealth Management | Page 14 for providing advice and managing portfolios for the client. From time to time we may receive referrals from clients for new business. We do NOT compensate clients for such referrals. Goldenstone Wealth Management pays cash compensation to certain promoters for referring prospective clients to the firm. Promoters receiving referral compensation are required to comply with applicable federal and state regulatory requirements. If you were referred to Goldenstone by a promoter, you should have received this brochure and a separate written disclosure describing the referral arrangement at the time of the referral. If you engage Goldenstone for advisory services, the promoter will receive a portion of the advisory fees you pay. This compensation will continue for as long as you remain a client or until the referral agreement with the promoter is terminated. You do not pay additional fees or incur higher advisory costs as a result of this arrangement. Because promoters are compensated for referrals, they have a financial incentive to recommend Goldenstone, which creates a conflict of interest. You are under no obligation to engage Goldenstone. Similar advisory services may be available from other investment advisors at different fee levels. Promoters who maintain referral relationships with multiple advisory firms may have an additional incentive to recommend firms that provide higher compensation. Goldenstone requires promoters to disclose such relationships and conflicts of interest to prospective clients. Zoe Financial Referral Arrangement Goldenstone Wealth Management receives client referrals through its participation in the Zoe Advisor Network (“ZAN”), operated by Zoe Financial, Inc. Zoe Financial is an independent, unaffiliated entity, and there is no employment, ownership, or common control relationship between Zoe Financial and Goldenstone. Zoe Financial established ZAN to refer individuals seeking fee-only investment management or financial planning services to independent investment advisors. Zoe Financial does not supervise, direct, or control Goldenstone’s advisory services, investment recommendations, or client account management. Goldenstone pays Zoe Financial an ongoing referral fee for clients referred through ZAN. This fee is generally calculated as a percentage of the advisory fees paid by the client to Goldenstone and is commonly referred to as a promoter fee. Clients referred through ZAN do not pay advisory fees higher than Goldenstone’s standard fee schedule offered to similarly situated clients. Additional information regarding compensation paid, directly or indirectly, to Zoe Financial is provided in the Zoe Financial Disclosure and Acknowledgement Form. ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement Goldenstone Wealth Management | Page 15 Item 15: Custody As a matter of policy and practice, Goldenstone Wealth Management does not permit employees or the firm to accept or maintain custody of client assets. It is our policy that we will not accept, hold, directly or indirectly, client funds or securities, or have any authority to obtain possession of them, with the sole exception of direct debiting of advisory fees. Goldenstone Wealth Management will not intentionally take custody of client cash or securities. However, Goldenstone Wealth Management may be deemed to have custody of assets due to Standing Letters of Authorization and consequently having third-party money movement authority over client accounts. All of our clients receive monthly and at least quarterly account statements directly from their custodians. The Client’s assets are held in custody with a third-party firm in their name. Goldenstone does not take ownership of any of your assets or accounts, and we simply serve as discretionary advisors and fiduciaries. We ask our clients to choose a third-party discount brokerage house for the purpose of holding the assets and providing detailed record- keeping. Clients are advised to review the statements received from the custodian upon receipt, and also compare them to the statements they receive from us. Goldenstone will be directly deducting advisory fees from the account held at the respective custodian. Any fees deducted will appear on statements received from Charles Schwab. Per the SEC’s Division of Investment Management granted no-action relief to advisers with custody due to authority granted under third-party SLOAs, (Rule 206(4)-2 (“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”), Goldenstone provides the following protections regarding the qualified custodian when deemed to have custody due to third party SLOAs by ensuring the following steps are completed: • Client Authorization: The client must provide written authorization to the qualified custodian to allow the adviser to transfer funds to a third party. • Designated Third Party: The client must designate the third party in the written authorization. • Custodian Oversight: The qualified custodian must receive a copy of the written authorization from the client. • Transfers to Designated Accounts Only: Goldenstone can only send funds to the designated third party at a specified account. • Client Can Modify or Revoke: The client must be able to change or revoke the Standing Letter Of Authorization (SLOA). • Custodian Confirmation: The custodian sends confirmations of transfers to the client as requested. ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement Goldenstone Wealth Management | Page 16 • No Adviser Modification Authority: Goldenstone cannot modify any details of the designated third party (name, address, account number, etc.). • Third Party is not related to any advisor at Goldenstone, or located at the same address as Goldenstone. Item 16: Investment Discretion To work with Goldenstone, client will engage in a discretionary plan where all investment decisions are made by Goldenstone as your fiduciary. These decisions follow a previously agreed upon plan, which is your unique investment policy statement. Clients may choose to give us full discretionary authority, or place restrictions on us on the types of securities, companies, or investments we may pursue. All such restrictions will be clearly documented in the investment policy statement, as well as the client agreement. These restrictions will be reviewed during client meetings, at least annually. Goldenstone has discretionary authority to determine the securities to be bought or sold for a client's account and the securities to be bought or sold for a client's account. Item 17: Voting Client Securities We do not accept the proxy authority to vote client securities. Clients will receive proxies or other solicitations directly from their custodian or a transfer agent. Clients may call, write or email us to discuss questions they may have about particular proxy votes or other solicitations. Clients maintain 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. Therefore, our firm and/or you shall instruct your qualified custodian to forward to you copies of all proxies and shareholder communications relating to your investment assets. Item 18: Financial Information It is our policy that we will not accept, hold, directly or indirectly, client funds or securities, or have any authority to obtain possession of them, with the sole exception of direct debiting of advisory fees. Goldenstone Wealth Management will not intentionally take custody of client cash or securities. However, Goldenstone Wealth Management may be deemed to have custody of assets due to Standing Letters of Authorization and consequently having third-party money movement authority over client accounts. We do NOT require or solicit prepayment of more than $1,200 in fees per client (per state securities authorities registration requirements), six months or more in advance under any circumstances. We do NOT have any financial condition that is reasonably likely to impair our ability to meet contractual commitments to clients. We have NOT been the subject of a bankruptcy petition at any time during the past ten years. ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement Goldenstone Wealth Management | Page 17 Part 2B of Form ADV Brochure Supplement Item 1: Cover Page Sanjay Varshney, PhD, CFA Advisor CRD # 4721550 Business Address: 5170 Golden Foothill Parkway, El Dorado Hills CA 95762 (916) 799-6527 Goldenstone Wealth Management Firm CRD: 310041 5170 Golden Foothill Parkway El Dorado Hills CA 95762 Firm Website Address: www.goldenstonewealth.com This brochure supplement provides information about Sanjay Varshney, PhD, CFA that supplements Goldenstone Wealth Management firm brochure. You should have received a copy of that brochure. Please contact Sanjay Varshney, PhD, CFA (Chief Compliance Officer) by telephone at (916) 799-6527 or contact@goldenstonewealth.com if you did not receive the Goldenstone Wealth Management’s Brochure or if you have any questions about the contents of this supplement. Additional information about the firm and its representatives is available on the SEC’s website at www.adviserinfo.sec.gov. ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement Goldenstone Wealth Management | Page 18 Item 2 Education Background and Business Experience Sanjay Varshney, PhD, CFA – Founder and Principal Year of Birth: 1967 Dr. Sanjay Varshney, CFA has over experience in the investments industry for over three decades. Prior to founding Goldenstone, he was a senior wealth management executive for six years at Wells Fargo Private Bank, serving as a Senior Vice President and a Senior Investment Strategist for California and Nevada, providing leadership and investment strategy for over $200 billion in assets. Dr. Varshney is also a Professor of Finance at Sacramento State, contributes to the local economic forecasts in the Greater Sacramento region, and has conducted numerous business and economic impact studies. Dr. Varshney earned an undergraduate degree in Accounting and Financial Management from Bombay University, a Master’s degree in Economics from the University of Cincinnati, and a PhD in Finance from Louisiana State University in Baton Rouge. He also holds the Chartered Financial Analyst (CFA®) designation. Employment History for Sanjay Varshney, PhD, CFA From To Address Position Held Investment related 07/2020 Present Yes Principal Name of Firm of Company Goldenstone Wealth Management El Dorado Hills, CA Sacramento, CA 01/2015 Present No Professor California State University 03/2015 06/2020 Wells Fargo Private Roseville, CA Yes Bank Senior Vice President 10/2014 03/2015 Yes El Dorado Hills, CA Senior Vice President Wells Fargo Advisors, LLC Sacramento, CA 07/2004 12/2014 No Dean California State University Chartered Financial Analyst (CFA): The Chartered Financial Analyst (CFA) charter is a globally respected, graduate-level investment credential established in 1962 and awarded by CFA Institute — the largest global association of investment professionals. There are currently more than 200,000 CFA charterholders around the world. To earn the CFA charter, candidates must: 1. Complete a bachelor's program or equivalent program and have received a degree from the college/university ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement Goldenstone Wealth Management | Page 19 2. Pass three sequential, six-hour examinations covering investment analysis, management, and ethics 3. Have at least four years of qualified professional investment experience 4. Obtain 2-3 professional letters of recommendation 5. Join the CFA Institute as members of the organization 6. Commit to abide by, and annually reaffirm, adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. High Ethical Standards The CFA Institute Code of Ethics and Standards of Professional Conduct, enforced through an active professional conduct program, require CFA charterholders to: 1. Place their clients’ interests ahead of their own 2. Maintain independence and objectivity 3. Act with integrity 4. Maintain and improve their professional competence 5. Disclose conflicts of interest and legal matters Global Recognition Passing the three CFA exams requires extensive study - on average a candidate spends over 900 hours of self-study. Additionally, regulatory bodies in 28 countries recognize the CFA charter as a proxy for meeting certain licensing requirements. Comprehensive and Current Knowledge The CFA Program curriculum provides a comprehensive framework of knowledge for investment decision making and is firmly grounded in the knowledge and skills used every day in the investment profession. The three levels of the CFA Program test a proficiency with a wide range of fundamental and advanced investment topics, including ethical and professional standards, fixed-income and equity analysis, alternative and derivative investments, economics, financial reporting standards, portfolio management, and wealth planning. For more information, please go to: https://www.cfainstitute.org/en/programs/cfa/charter Item 3 Disciplinary Information There are no legal or disciplinary events material to a client’s or prospective client’s evaluation of Dr. Sanjay Varshney, CFA. Item 4 Other Business Activities Dr. Sanjay Varshney, CFA is engaged in outside business activity as a Professor of Finance at ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement Goldenstone Wealth Management | Page 20 Sacramento State University, Sacramento, CA. He teaches courses in Managerial/Corporate Finance. His activities as Professor are not investment related. He has served as Professor since 01/2015 and spend approximately 36 hours per month teaching. Item 5 Additional Compensation Dr. Sanjay Varshney, CFA does NOT receive any performance-based compensation or any economic benefits to include sales awards and other prizes, or any bonus that is based, at least in part, on the number or amount of sales, client referrals, or new accounts. Item 6 Supervision Dr. Sanjay Varshney, CFA as Principal and Advisor is supervised by Andres Villegas, CFA Principal and Advisor (Telephone: 915-726-8262) at Goldenstone Wealth Management. This supervision extends to reviewing business practices, trading and ensuring the firm is adhering to applicable laws, regulations and firm policies. He can be reached at (915)-726-8262. ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement Goldenstone Wealth Management | Page 21 Part 2B of Form ADV Brochure Supplement Item 1: Cover Page Andres Villegas, CFA Advisor CRD # 7274223 Business Address: 5170 Golden Foothill Parkway, El Dorado Hills CA 95762 (915) 726-8262 Goldenstone Wealth Management Firm CRD: 310041 5170 Golden Foothill Parkway El Dorado Hills CA 95762 Firm Website Address: www.goldenstonewealth.com This brochure supplement provides information about Andres Villegas, CFA that supplements Goldenstone Wealth Management firm brochure. You should have received a copy of that brochure. Please contact Sanjay Varshney, PhD, CFA (Chief Compliance Officer) by telephone at (916) 799-6527 or contact@goldenstonewealth.com if you did not receive the Goldenstone Wealth Management’s Brochure or if you have any questions about the contents of this supplement. Additional information about the firm and its representatives is available on the SEC’s website at www.adviserinfo.sec.gov. ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement Goldenstone Wealth Management | Page 22 Item 2 Education Background and Business Experience Andres Villegas, CFA – Founder and Principal Year of Birth: 1990 Andres Villegas is a portfolio investment manager having served the wealth and investment management needs of families, businesses, and nonprofit organizations in Texas, New Mexico, and California. Prior to founding Goldenstone, Andres was a Vice President and Investment Strategist at Wells Fargo Private Bank for nearly 10 years, managing over $400 million in assets. His previous background includes portfolio and investment management for clients from Latin America. Andres earned an undergraduate degree in Finance from the McCombs School of Business at The University of Texas at Austin. He also attended a business program at The University of Chicago Booth School of Business. He holds the Chartered Financial Analyst (CFA®) designation. Andres contributes regularly to the local economic forecasts in the Greater Sacramento region. Employment History for Andres Villegas, CFA From To Address Name of Firm of Company Investment related Position Held 07/2020 Present Yes Principal 04/2012 06/2020 Yes El Dorado Hills, CA Roseville, CA 01/2010 04/2012 Austin, TX No Goldenstone Wealth Management Wells Fargo Private Bank The University of Texas at Austin Investment Strategist Student/ Assistant Chartered Financial Analyst (CFA): The Chartered Financial Analyst (CFA) charter is a globally respected, graduate-level investment credential established in 1962 and awarded by CFA Institute — the largest global association of investment professionals. There are currently more than 200,000 CFA charterholders around the world. To earn the CFA charter, candidates must: 1. Complete a bachelor's program or equivalent program and have received a degree from the college/university 2. Pass three sequential, six-hour examinations covering investment analysis, management, and ethics 3. Have at least four years of qualified professional investment experience 4. Obtain 2-3 professional letters of recommendation 5. Join the CFA Institute as members of the organization ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement Goldenstone Wealth Management | Page 23 6. Commit to abide by, and annually reaffirm, adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. High Ethical Standards The CFA Institute Code of Ethics and Standards of Professional Conduct, enforced through an active professional conduct program, require CFA charterholders to: 1. Place their clients’ interests ahead of their own 2. Maintain independence and objectivity 3. Act with integrity 4. Maintain and improve their professional competence 5. Disclose conflicts of interest and legal matters Global Recognition Passing the three CFA exams requires extensive study - on average a candidate spends over 900 hours of self-study. Additionally, regulatory bodies in 28 countries recognize the CFA charter as a proxy for meeting certain licensing requirements. Comprehensive and Current Knowledge The CFA Program curriculum provides a comprehensive framework of knowledge for investment decision making and is firmly grounded in the knowledge and skills used every day in the investment profession. The three levels of the CFA Program test a proficiency with a wide range of fundamental and advanced investment topics, including ethical and professional standards, fixed-income and equity analysis, alternative and derivative investments, economics, financial reporting standards, portfolio management, and wealth planning. For more information, please go to: https://www.cfainstitute.org/en/programs/cfa/charter Item 3 Disciplinary Information There are no legal or disciplinary events material to a client’s or prospective client’s evaluation of Andres Villegas, CFA. Item 4 Other Business Activities Andres Villegas, CFA is NOT engaged in other outside business activity. ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement Goldenstone Wealth Management | Page 24 Item 5 Additional Compensation Andres Villegas, CFA does NOT receive any performance-based compensation or any economic benefits to include sales awards and other prizes, or any bonus that is based, at least in part, on the number or amount of sales, client referrals, or new accounts. Item 6 Supervision Andres Villegas, CFA as Principal and Advisor is supervised by Dr. Sanjay Varshney, CFA, Principal and Advisor (Telephone: 916) 799-6527) at Goldenstone Wealth Management. This supervision extends to reviewing business practices, trading and ensuring the firm is adhering to applicable laws, regulations and firm policies. He can be reached at (916) 799-6527. ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement Goldenstone Wealth Management | Page 25

Frequently Asked Questions