GREENLINE WEALTH MANAGEMENT

F O R M A D V P A R T 2 A F I R M B R O C H U R E Office Address: 301 Yamato Road Suite 3151 Boca Raton, FL 33431 Email: info@greenlinewm.com Phone: 561.405.6609 Website: www.greenlinewm.com APRIL 2, 2026 This brochure provides information about the qualifications and business practices of Greenline Wealth Management LLC. Being registered as a registered investment adviser does not imply a certain level of skill or training. If you have any questions about the contents of this brochure, please contact us at 561.405.6609. 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 Greenline Wealth Management LLC (CRD #298397) is available on the SEC’s website at www.adviserinfo.sec.gov i | P a g e  Item 2: Material Changes Annual Update The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of the Firm Brochure. Material Changes since the Last Update Since the last update on February 26, 2026, the following changes have occurred: • The brochure has been updated for SEC registration. Full Brochure Available This Firm Brochure being delivered is the complete brochure for the Firm. ii | P a g e  Item 3: Table of Contents Form ADV – Part 2A – Firm Brochure Item 1: Cover Page Item 2: Material Changes .................................................................................................................... ii Annual Update ................................................................................................................................................................... ii Material Changes since the Last Update.................................................................................................................. ii Full Brochure Available .................................................................................................................................................. ii Item 3: Table of Contents ................................................................................................................... iii Item 4: Advisory Business .................................................................................................................. 1 Firm Description ............................................................................................................................................................... 1 Types of Advisory Services ........................................................................................................................................... 1 Client Tailored Services and Client Imposed Restrictions ............................................................................... 5 Wrap Fee Programs ......................................................................................................................................................... 6 Client Assets Under Management .............................................................................................................................. 6 Item 5: Fees and Compensation ....................................................................................................... 6 Method of Compensation and Fee Schedule .......................................................................................................... 6 Client Payment of Fees ................................................................................................................................................ 10 Additional Client Fees Charged ................................................................................................................................ 10 Prepayment of Client Fees ......................................................................................................................................... 11 External Compensation for the Sale of Securities to Clients ........................................................................ 11 Item 6: Performance-Based Fees and Side-by-Side Management ...................................... 11 Sharing of Capital Gains .............................................................................................................................................. 11 Item 7: Types of Clients ..................................................................................................................... 11 Description ....................................................................................................................................................................... 11 Account Minimums ....................................................................................................................................................... 11 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss .............................. 11 Methods of Analysis ...................................................................................................................................................... 11 Investment Strategy ..................................................................................................................................................... 12 Security Specific Material Risks ............................................................................................................................... 12 Item 9: Disciplinary Information ................................................................................................... 14 Criminal or Civil Actions ............................................................................................................................................. 14 Administrative Enforcement Proceedings .......................................................................................................... 14 iii | P a g e  Self- Regulatory Organization Enforcement Proceedings ............................................................................ 14 Item 10: Other Financial Industry Activities and Affiliations ............................................. 14 Broker-Dealer or Representative Registration ................................................................................................. 14 Futures or Commodity Registration ...................................................................................................................... 14 Material Relationships Maintained by this Advisory Business and Conflicts of Interest ................ 14 Recommendations or Selections of Other Investment Advisors and Conflicts of Interest ............. 15 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................................................................................................................................................... 15 Code of Ethics Description ......................................................................................................................................... 15 Investment Recommendations Involving a Material Financial Interest and Conflict of Interest. 16 Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest 16 Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest .................................................................................................................. 16 Item 12: Brokerage Practices ......................................................................................................... 16 Factors Used to Select Broker-Dealers for Client Transactions ................................................................. 16 Aggregating Securities Transactions for Client Accounts ............................................................................. 17 Item 13: Review of Accounts ........................................................................................................... 17 Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved ............................................................................................................................................................................. 17 Review of Client Accounts on Non-Periodic Basis ........................................................................................... 17 Content of Client Provided Reports and Frequency ........................................................................................ 17 Item 14: Client Referrals and Other Compensation ................................................................ 18 Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest ............................................................................................................................................................................... 18 Advisory Firm Payments for Client Referrals .................................................................................................... 18 Item 15: Custody .................................................................................................................................. 18 Account Statements ...................................................................................................................................................... 18 Item 16: Investment Discretion ..................................................................................................... 18 Discretionary Authority for Trading...................................................................................................................... 18 Item 17: Voting Client Securities ................................................................................................... 18 Proxy Votes ...................................................................................................................................................................... 18 Item 18: Financial Information ...................................................................................................... 19 Balance Sheet .................................................................................................................................................................. 19 iv | P a g e  Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients ............................................................................................................................................................................ 19 Bankruptcy Petitions during the Past Ten Years .............................................................................................. 19 Brochure Supplement (Part 2B of Form ADV) .......................................................................... 21 Principal Executive Officer - Christopher N. Gacom, CRPC® ........................................................................ 21 Item 2 - Educational Background and Business Experience ....................................................................... 21 Item 3 - Disciplinary Information ........................................................................................................................... 21 Item 4 - Other Business Activities Engaged In ................................................................................................... 22 Item 5 - Additional Compensation .......................................................................................................................... 22 Item 6 - Supervision ..................................................................................................................................................... 22 Brochure Supplement (Part 2B of Form ADV) .......................................................................... 24 Stephen V. Gagliardi, CRPS® ...................................................................................................................................... 24 Item 2 - Educational Background and Business Experience ....................................................................... 24 Item 3 - Disciplinary Information ........................................................................................................................... 24 Item 4 - Other Business Activities Engaged In ................................................................................................... 24 Item 5 - Additional Compensation .......................................................................................................................... 25 Item 6 - Supervision ..................................................................................................................................................... 25 v | P a g e  Item 4: Advisory Business Firm Description Greenline Wealth Management LLC doing business as (dba) Greenline Wealth Management (“GWM”) was founded in 2018. Christopher N. Gacom is 60% owner and Stephen V. Gagliardi is 40% owner. Christopher N. Gacom will act as the principal and Stephen Gagliardi will act as the Chief Compliance Officer of the firm. Types of Advisory Services ASSET MANAGEMENT GWM offers discretionary and non-discretionary direct asset management services to advisory clients. GWM will offer clients ongoing portfolio management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. Discretionary When the client provides GWM discretionary authority the client will sign a limited trading authorization or equivalent. GWM will have the authority to execute transactions in the account without seeking client approval on each transaction. For additional information regarding discretionary authority, please see Item 16 of this brochure. Non-discretionary When the client elects to use GWM on a non-discretionary basis, GWM will determine the securities to be bought or sold and the amount of the securities to be bought or sold. However, GWM will obtain prior client approval on each and every transaction before executing any transactions. GWM also offers discretionary asset management through an agreement with Envestnet PMC “Envestnet” CRD number (111694) an SEC registered firm. Envestnet allowing GWM to use their Third Party Strategist network. Through this network, GWM will have access to numerous Third Party Money Managers and their portfolios. Using suitability forms and questionnaires, GWM will be able to determine which Third Party Manager and Portfolio's should be used for a specific Client. The Client's funds will be sent to the Custodian, Envestnet will execute the orders to invest in the selected portfolios. The Third Party Money Manager will manage the underlying investments within the selected portfolio. GWM has discretion to change managers and portfolios if we feel they aren't performing or no longer fit our Client's needs. ERISA PLAN SERVICES GWM provides service to qualified retirement plans including 401(k) plans, 403(b) plans, pension and profit-sharing plans, cash balance plans, and deferred compensation plans. GWM may act as either a 3(21) or 3(38) advisor: Limited Scope ERISA 3(21) Fiduciary - Retirement Plan Consulting. GWM may serve as a limited scope ERISA 3(21) fiduciary that can advise, help and assist plan sponsors with their investment decisions on a non-discretionary basis. As an investment advisor GWM has a fiduciary duty to act in the best interest of the Client. The plan sponsor is still Page | 1  ultimately responsible for the decisions made in their plan, though using GWM can help the plan sponsor delegate liability by following a diligent process. 1. Fiduciary Services are: • Provide non-discretionary investment advice to the Client about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. Client will make the final decision regarding the initial selection, retention, removal and addition of investment options. GWM acknowledges that it is a fiduciary as defined in ERISA section 3 (21) (A) (ii). • Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the IPS. • Provide non-discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5) and 404(a)-5. • Provide non-discretionary investment advice to the Plan Participant with respect to the following: o Developing an asset allocation that aligns with the Participant’s goals, current financial situation, and existing portfolio holdings, o Evaluating plan investment options, o Suggesting account changes, which are then enacted by the plan participant. • Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain, remove or replace investment options. • Meet with Client on a periodic basis to discuss the reports and the investment recommendations. 2. Non-fiduciary Services are: • Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. Client understands GWM’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). During such engagements, GWM is not providing fiduciary advice as defined by ERISA 3(21)(A)(ii) to the Plan participants. Advisor will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan. • Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. Page | 2  GWM may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between Advisor and Client. 3. GWM has no responsibility to provide services related to the following types of assets (“Excluded Assets”): • Employer securities; • Real estate (except for real estate funds or publicly traded REITs); • Stock brokerage accounts or mutual fund windows; • Participant loans; • Non-publicly traded partnership interests; • Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or • Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in calculation of Fees paid to GWM on the ERISA Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. ERISA 3(38) Investment Manager - Retirement Plan Asset Management. GWM can also act as an ERISA 3(38) Investment Manager in which it has discretionary management and control of a given retirement plan’s assets. GWM would then become solely responsible and liable for the selection, monitoring and replacement of the plan’s investment options. 1. Fiduciary Services are: • GWM has discretionary authority and will make the final decision regarding the initial selection, retention, removal and addition of investment options in accordance with the Plan’s investment policies and objectives. • Assist the Client with the selection of a broad range of investment options consistent with ERISA Section 404(c) and the regulations thereunder. • Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan. • Provide discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5). 2. Non-fiduciary Services are: • Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. Client understands GWM’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, GWM is not providing fiduciary advice as defined by ERISA to the Plan participants. GWM will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan. Page | 3  • Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. GWM may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between GWM and Client. 3. GWM has no responsibility to provide services related to the following types of assets (“Excluded Assets”): • Employer securities; • Real estate (except for real estate funds or publicly traded REITs); • Stock brokerage accounts or mutual fund windows; • Participant loans; • Non-publicly traded partnership interests; • Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or • Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in calculation of Fees paid to the Adviser on the ERISA Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. FINANCIAL PLANNING and CONSULTING Financial Planning If financial planning services are applicable, a thorough review of all applicable topics including but not limited to: • Wills, Estate Plans & Trusts: Estate planning - Reviewing your wills and trusts. intended heirs. Helping with beneficiary Preserving your estate for your designations. Reducing exposure to estate taxes and probate costs. Coordinating with your tax and legal advisors. • Investments: Investments - Determining your asset allocation needs. Helping you understand your risk tolerance. Recommending the appropriate investment vehicles to help you reach and exceed your goals. • Taxes: Tax planning – reviewing accounts to help ensure that they are set up using tax advantaged methods. Making recommendations for types of accounts to utilize to help benefit tax purposes in the present and in the future when taking for retirement purposes. • Qualified Plans, Retirement Income: Retirement planning - Making the most of your employer-sponsored retirement plans and IRAs. Determining how much you need to retire comfortably. Managing assets before and during retirement. • - Reviewing existing Insurance: Risk management insurance policies. Recommending policy changes when appropriate. Finding the best policy for your situation. • Social Security: Review social security options and benefit to ensure the appropriate time to begin receiving benefits. Page | 4  • College Planning: Education funding - Recommending investment and accumulation strategies to help you pay for your children's education. If a conflict of interest exists between the interests of GWM and the interests of the Client, the Client is under no obligation to act upon GWM’s recommendation. If the Client elects to act on any of the recommendations, the Client is under no obligation to effect the transaction through GWM. Financial plans will be completed and delivered inside of ninety (90) days contingent upon timely delivery of all required documentation. Financial Consulting Clients may also participate in on-going financial consulting services. Ongoing services will continue from year to year unless cancelled by either party. When participating in ongoing services, clients can expect the following: • At least one meeting to determine financial goals and values • At least one meeting to deliver recommendations and action items. • Periodic meetings to discuss goals, monitor progress and update any changes. • Ongoing check-ins via phone or email for accountability and to address changes Retirement Plans GWM may also provide retirement plan investment advisory services on an "unbundled" basis or may perform individual projects for an agreed upon fee. For example, GWM may be retained only to provide regular performance measurement reports (such as for a pension or 401(k) plan), with other activities being priced on an "as used" basis, or GWM may be asked to perform benchmarking services or a one-time search for a recordkeeper service provider to a retirement plan. Assets Held Away When applicable, GWM will provide Clients advice on accounts not held with GWM. These assets are considered “held-away” assets and may include but are not limited to accounts such as 401(k) plans, other retirement plans, 529 plans, etc. Consulting may include: • Developing an asset allocation that aligns with the Client’s goals, current financial situation, and existing portfolio holdings, • Evaluating investment options, • Suggesting appropriate trades, which are then enacted by the Clients, • Monitoring the accounts based on information made available to GWM by the Clients, • Providing performance reporting on an ongoing basis, if requested. Investment consulting on held-away assets require the Client to provide account data to GWM on a regular basis or to make such data available to GWM. If a conflict of interest exists between the interests of GWM and the interests of the Client, the Client is under no obligation to act upon GWM’s recommendation. If the Client elects to act on any of the recommendations, the Client is under no obligation to effect the transaction through GWM. Financial consulting will continue from year to year unless cancelled by either party. Client Tailored Services and Client Imposed Restrictions Page | 5  The goals and objectives for each Client are documented in our Client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without written Client consent. Wrap Fee Programs GWM may utilize the services of Third Party Managers, via Envestnet, who offer wrap fee programs. This information will be disclosed in the Part 2A appendix wrap fee program brochure of the Third Party Managers. Client Assets Under Management GWM has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: $116,841,841 $128,278 Date Calculated: December 31, 2025 Additionally, GWM has $254,502,115 of Pension Consulting assets. Item 5: Fees and Compensation Method of Compensation and Fee Schedule ASSET MANAGEMENT GWM offers discretionary and non-discretionary direct asset management services to advisory Clients. GWM charges an annual investment advisory fee based on the total assets under management as follows: Assets Under Management $0 to $250,000 $250,001 to $500,000 $500,001 to $1,000,000 Over $1,000,000 Annual Fee 1.50% 1.25% 1.00% 0.90% Monthly Fee 0.125% 0.104% 0.083% 0.075% This is a flat rate/breakpoint fee schedule, the entire portfolio is charged the same asset management fee. For example, a Client with $750,000 under management would pay $7,500 on an annual basis. $750,000 x 1.00% = $7,500. (AUM x Annual Fee = Annual Advisory Fee). The annual fee is negotiable based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with Clients, etc.). Fees are billed monthly in arrears based on the amount of assets managed as of the close of business on the last business day of the previous month. Total fees to Client will never exceed the safe harbor threshold of 3% of assets under management per year. Lower fees for comparable services may be available from other sources. Clients may terminate their account within five (5) business days of signing the Investment Advisory Agreement with no obligation and without penalty. After the initial five (5) business days, the agreement may be terminated by GWM with thirty (30) days written notice to Client and by the Client at any time with written notice to GWM. No fee adjustment will be made for account deposits and/or withdrawals during a billing period. For accounts opened or closed mid-billing period, fees will be prorated based on the days services are provided during the given period. All unpaid earned fees will be due to GWM. Client shall be given Page | 6  thirty (30) days prior written notice of any increase in fees. Any increase in fees will be acknowledged in writing by both parties before any increase in said fees occurs. Envestnet Fund Strategist Network Fees Under this program, the Envestnet Platform Fee, and the Third Party Manager Fee are bundled together. The Envestnet Program Fee (Envestnet and Manager) will be 60 to 90 basis points. The total fee will be disclosed and agreed upon in the Investment Advisory Agreement each Client will be given. This total bundled fee is in addition to the Custodian Fees and GWM’s fees. GWM’s fees when using Envestnet are as follows: Assets Under Management $0 to $250,000 $250,001 to $500,000 $500,001 to $1,000,000 Over $1,000,000 Annual Fee 1.50% 1.25% 1.0% 0.90% Monthly Fee 0.125% 0.104% 0.083% 0.075% GWM’s annual Fee may be negotiable. Envestnet Fees are billed quarterly in advance. Envestnet’s billing services calculates the fees for Envestnet, GWM, the custody fee, and the manager fee will be billed in accordance with the fee schedule above. Total fees to Client will never exceed the safe harbor threshold of 3% of assets under management per year. For Clients located in the State of Kentucky the fees will never exceed 2%. Monthly prorates are run to capture additional deposits or withdrawals and intra quarter account opening and closings. As soon as possible after the end of each calendar quarter, Envestnet will either mail quarterly performance statements or obtain the necessary consent from each Client wherein such Client agrees to electronic delivery. The performance statement includes a description of all activity in each Client’s account(s) during the previous quarter, including all of the following: (i) an asset summary and performance section, (ii) comparative indices, (iii) all transactions made on behalf of the account(s), (iv) all contributions and withdrawals made by the Client, and (v) information indicating the market value of the account(s) at the beginning and end of the period, as well as the cost and market value of each of the Program Assets. Fees collected by Envestnet from the Client account will be distributed to the appropriate parties for payment. Lower fees for comparable services may be available from other sources. Clients may terminate their account within five business days of signing the Investment Advisory Agreement with no obligation. Clients may terminate advisory services with thirty (30) days written notice. Client will be entitled to a pro rata refund for the days service was not provided in the final quarter. Client shall be given thirty (30) days prior written notice of any increase in fees. Fee Billing Calculation For Envestnet Advisor relationships, the Program Fees charged are calculated by Envestnet as an annual percentage of assets based on the market value of the account at the end of quarter. Program Fees are charged on a calendar quarter basis in advance and prorated to the end of the quarter upon inception of the account. The level of the Program Fee will vary Page | 7  with the amount of assets under management and the particular investment styles and investment options chosen or recommended. Clients may receive comparable services from other sources for fees that are lower or higher than those charged by Envestnet. When making adjustments for a new account in advance, the portion of the fee attributed to the portfolio will be subtracted while it was not under management as shown below: Number of days not in management divided by number of days in billing period multiplied by the total fee: # of days not in management __________________________________________ X fee # of days in billing period ERISA PLAN SERVICES Limited Scope ERISA 3(21) Fiduciary - Retirement Plan Consulting: The total estimated fee, as well as the ultimate fee that we charge you, is based on the scope and complexity of our engagement with you. Our maximum annualized percentage-based fee for this service is 1.00% of the assets under management. We may also charge on a fixed fee basis, in which case, our fees will range from $500-$300,000. Our firms’ percentage-based fees are billed on a pro-rata annualized basis monthly or quarterly in advance or arrears based on the daily average value of the plan assets as of the last day of the month or quarter. However, we occasionally accommodate client requests for individually tailored billing cycles. The fees listed are the maximum fees charged for services. Each client’s fees are negotiated on a case by case basis. Average client fees are typically lower than the maximum fee quoted above. ERISA 3(38) Investment Manager - Retirement Plan Asset Management: The total estimated fee, as well as the ultimate fee that we charge you, is based on the scope and complexity of our engagement with you. Our maximum annualized fee for this service is 1.00% of the assets under management. The fees charged for retirement plan asset management services under 3(38) takes into account the fees listed as part of our Retirement Plan Consulting service and additional fees in exchange for other services that may be provided. We may also charge on a fixed fee basis, in which case, our fees will range from $500-$300,000. The fees listed are the maximum fees charged for services. Average client fees are typically lower than the maximum fee quoted above. Fees are calculated by the custodian or record keeper of the Included Assets (without adjustments for anticipated withdrawals by Plan participants or other anticipated or scheduled transfers or distribution of assets). If the services to be provided start any time other than the first day of a quarter or month, the fee will be prorated based on the number of days remaining in the quarter or month. If this Agreement is terminated prior to the end of the billing cycle, GWM shall be entitled to a prorated fee based on the number of days during the fee period services were provided or Client will be due a prorated refund of fees for days services were not provided in the billing cycle. The fee schedule, which includes compensation of GWM for the services is described in detail in Schedule A of the ERISA Plan Agreement. The Plan is obligated to pay the fees; however, the Plan Sponsor may elect to pay the fees. Client may elect to be billed directly or have fees deducted from Plan Assets. GWM does not reasonably expect to receive any Page | 8  additional compensation, directly or indirectly, for its services under this Agreement. If additional compensation is received, GWM will disclose this compensation, the services rendered, and the payer of compensation. GWM will offset the compensation against the fees agreed upon under the Agreement. Prior to the planning process the Client will be provided an estimated plan fee. Services are completed and delivered inside of ninety (90) days contingent upon timely delivery of all required documentation. Client may cancel within five (5) business days of signing Agreement with no obligation and without penalty. If the Client cancels after five (5) business days, any unearned fees will be refunded to the Client, or any unpaid earned fees will be due to GWM. GWM reserves the right to waive the fee should the Client implement the plan through GWM. FINANCIAL PLANNING and CONSULTING Financial Planning GWM charges either an hourly fee or fixed fee for financial planning. Prior to the planning process the Client will be provided an estimated plan fee. Services are completed and delivered inside of ninety (90) days contingent upon timely delivery of all required documentation. HOURLY FEES Financial Planning Services are offered based on an hourly fee of $200 per hour. FIXED FEES Financial Planning Services are offered based on a flat fee between $500 and $2,500. Fees will be charged according to the chart below: Services Wills, Estate Plans & Trusts Investments Taxes Qualified Plans, Retirement Income Insurance Social Security College Planning Fixed Fee $750 $500 $650 $500 $500 $250 $250 Estimated Hours 4-8 2-4 4-6 2-4 2-4 1-3 1-3 Fees for financial plans are billed 50% in advance with the balance due upon plan delivery. Client may cancel within five (5) business days of signing Agreement with no obligation and without penalty. If the Client cancels after five (5) business days, any unearned fees will be refunded to the Client, or any unpaid earned fees will be due to GWM. GWM reserves the right to waive the fee should the Client implement the plan through GWM. Refunds will be based upon the amount of time spent preparing the plan. For example, if the fee is $2,000, and the client decides to cancel services, refunds will be calculated by determining the amount of time spent times the hourly rate of $200. For example, 3 hours of time spent x $200 = $600 (based upon 50% being paid in advance). The refund would be $400. Financial Consulting GWM charges an ongoing fixed or hourly fee for financial consulting. Prior to the planning process the Client will be provided an estimated plan fee. Financial consulting will continue from year to year unless cancelled by either party. Page | 9  HOURLY FEES Financial Planning Services are offered based on an hourly fee of $250 per hour. FIXED FEES Financial Planning Services are offered based on a flat fee between $500 and $10,000. Fees for financial consulting are billed monthly or quarterly in arrears. Client will either pay 12 equal payments or four equal payments as agreed upon in the Financial Planning and Consulting agreement. Payment may be paid via the following methods: • check to be remitted to GWM, • deducted from an account managed by GWM • deducted from an outside account identified by the Client via: o ACH o Debit Card o Credit Card (MasterCard, Visa, American Express, Discover) o Brokerage Accounts (when debits are enabled on the brokerage account). Client must approve in writing to have fees deducted from an account managed by GWM. Client may cancel within five (5) business days of signing Agreement with no obligation and without penalty. If the Client cancels after five (5) business days, any unearned fees will be refunded to the Client, or any unpaid earned fees will be due to GWM. GWM reserves the right to waive the fee should the Client implement the plan through GWM. Client Payment of Fees Fees for asset management services are: • Deducted from a designated Client account. The Client must consent in advance to direct debiting of their investment account. Fees for ERISA services will either be deducted from Plan assets or paid directly to GWM. The Client must consent in advance to direct debiting of their investment account. Fees for financial plans will be billed: • Deducted from a non-qualified designated Client account managed by GWM. The Client must consent in advance to direct debiting of their investment account. • Check – to be remitted by Client to GWM • Electronic Payment via ACH, Debit Card, or Credit Card (fees will be paid via a third party payment processor in which the client will securely input payment information and pay the advisory fee through a secure portal. GWM will not have continuous access to the Client’s banking information.) Additional Client Fees Charged Custodians may charge transaction fees on purchases or sales of certain mutual funds, equities, and exchange-traded funds. These charges may include mutual fund transaction fees, postage and handling, and miscellaneous fees. Page | 10  For more details on the brokerage practices, see Item 12 of this brochure. Prepayment of Client Fees Fees for ERISA 3(21) and/or 3(38) services may be billed in advance. Fees for financial plans are billed 50% in advance with the balance due upon plan delivery. If the Client cancels after five (5) business days, any unearned fees will be refunded to the Client, or any unpaid earned fees will be due to GWM. External Compensation for the Sale of Securities to Clients GWM does not receive any external compensation for the sale of securities to Clients, nor do any of the investment advisor representatives of GWM. Item 6: Performance-Based Fees and Side-by-Side Management Sharing of Capital Gains Fees are not based on a share of the capital gains or capital appreciation of managed securities. GWM does not use a performance-based fee structure because of the conflict of interest. Performance based compensation may create an incentive for GWM to recommend an investment that may carry a higher degree of risk to the Client. Item 7: Types of Clients Description GWM generally provides investment advice to individuals, high net worth individuals, trusts, estates, or charitable organizations, corporations or business entities. Client relationships vary in scope and length of service. Account Minimums GWM generally requires a minimum of $100,000 to open an account. In certain instances, the minimum account size may be lowered or waived. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include fundamental analysis, technical analysis, and charting analysis. Investing in securities involves risk of loss that Clients should be prepared to bear. Past performance is not a guarantee of future returns. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not take into account new patterns that emerge over time. Page | 11  Charting analysis strategy involves using and comparing various charts to predict long and short-term performance or market trends. The risk involved in using this method is that only past performance data is considered without using other methods to crosscheck data. Using charting analysis without other methods of analysis would be making the assumption that past performance will be indicative of future performance. This may not be the case. In developing a financial plan for a Client, GWM’s analysis may include cash flow analysis, investment planning, risk management, tax planning and estate planning. Based on the information gathered, a detailed strategy is tailored to the Client’s specific situation. The main sources of information include financial newspapers and magazines, annual reports, prospectuses, and filings with the Securities and Exchange Commission. Investment Strategy The investment strategy for a specific Client is based upon the objectives stated by the Client during consultations. The Client may change these objectives at any time by providing written notice to GWM. Each Client executes a Client profile form or similar form that documents their objectives and their desired investment strategy. Other strategies may include long-term purchases, short-term purchases, trading, and option writing (including covered options, uncovered options or spreading strategies). Security Specific Material Risks All investment programs have certain risks that are borne by the investor. Our investment approach constantly keeps the risk of loss in mind. Investors face the following investment risks and should discuss these risks with GWM: • Market Risk: The prices of securities held by mutual funds in which Clients invest may decline in response to certain events taking place around the world, including those directly involving the companies whose securities are owned by a fund; conditions affecting the general economy; overall market changes; local, regional or global political, social or economic instability; and currency, interest rate and commodity price fluctuations. Investors should have a long-term perspective and be able to tolerate potentially sharp declines in market value. • Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. • Inflation Risk: When any type of inflation is present, a dollar today will buy more than a dollar next year, because purchasing power is eroding at the rate of inflation. • Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. • Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized Page | 12  product. For example, Treasury Bills are highly liquid, while real estate properties are not. • Management Risk: The advisor’s investment approach may fail to produce the intended results. If the advisor’s assumptions regarding the performance of a specific asset class or fund are not realized in the expected time frame, the overall performance of the Client’s portfolio may suffer. • Equity Risk: Equity securities tend to be more volatile than other investment choices. The value of an individual mutual fund or ETF can be more volatile than the market as a whole. This volatility affects the value of the Client’s overall portfolio. Small- and mid-cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product lines, financial resources, and less management experience than larger companies. Smaller companies may also have a lower trading volume, which may disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. • Fixed Income Risk: The issuer of a fixed income security may not be able to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower rating, the value of the debt security will decline because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities held by a fund is likely to decrease. A nominal interest rate is the sum of a real interest rate and an expected inflation rate. • Investment Companies Risk: When a Client invests in open end mutual funds or ETFs, the Client indirectly bears their proportionate share of any fees and expenses payable directly by those funds. Therefore, the Client will incur higher expenses, which may be duplicative. In addition, the Client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value or (ii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de- listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. Adviser has no control over the risks taken by the underlying funds in which Client invests. • Long-term purchases: Long-term investments are those vehicles purchased with the intension of being held for more than one year. Typically, the expectation of the investment is to increase in value so that it can eventually be sold for a profit. In addition, there may be an expectation for the investment to provide income. One of the biggest risks associated with long-term investments is volatility, the fluctuations in the financial markets that can cause investments to lose value. • Short-term purchases: Short-term investments are typically held for one year or less. Generally, there is not a high expectation for a return or an increase in value. Typically, short-term investments are purchased for the relatively greater degree of principal protection they are designed to provide. Short-term investment vehicles Page | 13  may be subject to purchasing power risk — the risk that your investment’s return will not keep up with inflation. • Trading risk: Investing involves risk, including possible loss of principal. There is no assurance that the investment objective of any fund or investment will be achieved. • Options Trading: The risks involved with trading options are that they are very time sensitive investments. An options contract is generally a few months. The buyer of an option could lose his or her entire investment even with a correct prediction about the direction and magnitude of a particular price change if the price change does not occur in the relevant time period (i.e., before the option expires). Additionally, options are less tangible than some other investments. An option is a “book-entry” only investment without a paper certificate of ownership. • Leveraged Risk: The risks involved with using leverage may include compounding of returns (this works both ways – positive and negative), possible reset periods, volatility, use of derivatives, active trading and high expenses. • Structured Notes Risk: The risks involved with using structured notes are credit risk of the issuing investment bank, illiquidity, and there is a risk to the pricing accuracy as most structured notes do not trade after issuance. Item 9: Disciplinary Information Criminal or Civil Actions GWM and its management have not been involved in any criminal or civil action. Administrative Enforcement Proceedings GWM and its management have not been involved in administrative enforcement proceedings. Self- Regulatory Organization Enforcement Proceedings GWM and its management have not been involved in legal or disciplinary events that are material to a Client’s or prospective Client’s evaluation of GWM or the integrity of its management. Item 10: Other Financial Industry Activities and Affiliations Broker-Dealer or Representative Registration GWM is not registered nor have an application pending to register as a broker-dealer and no affiliated representatives of GWM are registered representatives nor have an application pending to register with a broker-dealer. Futures or Commodity Registration Neither GWM nor its affiliated representatives are registered or have an application pending to register as a futures commission merchant, commodity pool operator, or a commodity trading advisor. Material Relationships Maintained by this Advisory Business and Conflicts of Interest Investment Advisor Representatives of GWM are also licensed insurance agents with Greenline Insurance LLC. Approximately 15% of their time is spent on this practice. Christopher Gacom is insurance licensed in the states of Florida, Michigan, Illinois, New Page | 14  Jersey, and North Carolina. He will not offer insurance services to clients in Kentucky. From time to time, they will offer clients services from this activity. As insurance agents, they may receive separate yet typical commissions. This represents a conflict of interest because it gives an incentive to recommend products based on the commission amount received. This conflict is mitigated by disclosures, procedures, and both the investment advisor representative’s and the firm’s fiduciary obligation to place the best interest of the client first. Clients are not required to purchase any products and are not obligated to follow the recommendations of the investment advisor representative, or utilize their insurance services. Clients have the option to purchase these products through another insurance agent of their choosing. Additionally, Christopher Gacom and Stephen Gagliardi each have their own holding company for tax purposes. Christopher Gacom is 100% owner of Greenline Asset Management LLC and Greenline Ventures LLC. Stephen Gagliardi is 100% owner of Greenline Planning LLC. None of these companies pose a conflict of interest because they do not offer any services. Clients of GWM will not be solicited services for Greenline Asset Management LLC, Greenline Ventures LLC or Greenline Planning LLC. Recommendations or Selections of Other Investment Advisors and Conflicts of Interest GWM utilizes the wrap program through Envestnet described in Item 4 of this brochure. Since GWM has no incentive to select one manager portfolio over another, there is no conflict of interest. GWM ensures that before selecting other advisors for Client that the other advisors are properly licensed or registered as an investment advisor. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Description include employees and/or The affiliated persons (affiliated persons independent contractors) of GWM have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected of GWM affiliated persons and addresses conflicts that may arise. The Code defines acceptable behavior for affiliated persons of GWM. The Code reflects GWM and its supervised persons’ responsibility to act in the best interest of their Client. One area which the Code addresses is when affiliated persons buy or sell securities for their personal accounts and how to mitigate any conflict of interest with our Clients. We do not allow any affiliated persons to use non-public material information for their personal profit or to use internal research for their personal benefit in conflict with the benefit to our Clients. GWM’s policy prohibits any person from acting upon or otherwise misusing non-public or inside information. No advisory representative or other affiliated person, officer or director of GWM may recommend any transaction in a security or its derivative to advisory Clients or engage in personal securities transactions for a security or its derivatives if the advisory representative possesses material, non-public information regarding the security. GWM’s Code is based on the guiding principle that the interests of the Client are our top priority. GWM’s officers, directors, advisors, and other affiliated persons have a fiduciary duty to our Clients and must diligently perform that duty to maintain the complete trust Page | 15  and confidence of our Clients. When a conflict arises, it is our obligation to put the Client’s interests over the interests of either affiliated persons or the company. The Code applies to “access” persons. “Access” persons are affiliated persons who have access to non-public information regarding any Clients' purchase or sale of securities, or non-public information regarding the portfolio holdings of any reportable fund, who are involved in making securities recommendations to Clients, or who have access to such recommendations that are non-public. GWM will provide a copy of the Code of Ethics to any Client or prospective Client upon request. Investment Recommendations Involving a Material Financial Interest and Conflict of Interest GWM and its affiliated persons do not recommend to Clients securities in which we have a material financial interest. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest GWM and its affiliated persons may buy or sell securities that are also held by Clients. In order to mitigate conflicts of interest such as trading ahead of Client transactions, affiliated persons are required to disclose all reportable securities transactions as well as provide GWM with copies of their brokerage statements. The Chief Compliance Officer of GWM is Stephen Gagliardi. He reviews all trades of the affiliated persons each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets and that Clients of the firm receive preferential treatment over associated persons’ transactions. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest GWM does not maintain a firm proprietary trading account and does not have a material financial interest in any securities being recommended and therefore no conflicts of interest exist. However, affiliated persons may buy or sell securities at the same time they buy or sell securities for Clients. In order to mitigate conflicts of interest such as front running, affiliated persons are required to disclose all reportable securities transactions as well as provide GWM with copies of their brokerage statements. The Chief Compliance Officer of GWM is Stephen Gagliardi. He reviews all employee trades each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets and that Clients of the firm receive preferential treatment over associated persons’ transactions. Item 12: Brokerage Practices Factors Used to Select Broker-Dealers for Client Transactions GWM may recommend the use of a particular broker-dealer or may utilize a broker-dealer of the Client's choosing. GWM will select appropriate brokers based on a number of factors including but not limited to their relatively low transaction fees and reporting ability. GWM relies on its broker to provide its execution services at the best prices available. Lower fees for comparable services may be available from other sources. Clients pay for any and all custodial fees in addition to the advisory fee charged by GWM. Page | 16  GWM is not affiliated with the brokerage firm. Broker does not supervise GWM, its agents or activities. • Directed Brokerage In circumstances where a Client directs GWM to use a certain broker-dealer, GWM still has a fiduciary duty to its Clients. The following may apply with Directed Brokerage: GWM's inability to negotiate commissions, to obtain volume discounts, there may be a disparity in commission charges among Clients and conflicts of interest arising from brokerage firm referrals. • Best Execution Investment advisors who manage or supervise Client portfolios have a fiduciary obligation of best execution. The determination of what may constitute best execution and price in the execution of a securities transaction by a broker involves a number of considerations and is subjective. Factors affecting brokerage selection include the overall direct net economic result to the portfolios, the efficiency with which the transaction is effected, the ability to affect the transaction where a large block is involved, the operational facilities of the broker-dealer, the value of an ongoing relationship with such broker and the financial strength and stability of the broker. The firm does not receive any portion of the trading fees. • Soft Dollar Arrangements GWM does not receive soft dollar benefits. Aggregating Securities Transactions for Client Accounts GWM is authorized in its discretion to aggregate purchases and sales and other transactions made for the account with purchases and sales and transactions in the same securities for other Clients of GWM. All Clients participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rated basis. Item 13: Review of Accounts Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved Account reviews are performed quarterly by Stephen Gagliardi, the Chief Compliance Officer of GWM. Account reviews are performed more frequently when market conditions dictate. Reviews of Client accounts include, but are not limited to, a review of Client documented risk tolerance, adherence to account objectives, investment time horizon, and suitability criteria, reviewing target bans of each asset class to identify if there is an opportunity for rebalancing, and reviewing accounts for tax loss harvesting opportunities. Financial plans generated are updated as requested by the Client and pursuant to a new or amended agreement, GWM suggests updating at least annually. Review of Client Accounts on Non-Periodic Basis Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws, new investment information, and changes in a Client's own situation. Content of Client Provided Reports and Frequency Clients receive written account statements no less than quarterly for managed accounts. Account statements are issued by GWM’s custodian. Client receives confirmations of each Page | 17  transaction in account from Custodian and an additional statement during any month in which a transaction occurs. Item 14: Client Referrals and Other Compensation Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest GWM does not receive any economic benefits from external sources. Advisory Firm Payments for Client Referrals GWM does not compensate for Client referrals. Item 15: Custody Account Statements All assets are held at qualified custodians, which means the custodians provide account statements directly to Clients at their address of record at least quarterly. Clients are urged to compare the account statements received directly from their custodians to any documentation or reports prepared by GWM. GWM is deemed to have constructive custody solely because advisory fees are directly deducted from Client’s accounts by the custodian on behalf of GWM. GWM is not affiliated with the custodian. The custodian does not supervise GWM, its agents or activities. Item 16: Investment Discretion Discretionary Authority for Trading GWM may require discretionary authority to manage securities accounts on behalf of Clients. GWM has the authority to determine, without obtaining specific Client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. If applicable, Client will authorize GWM discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. GWM allows Client’s to place certain restrictions, as outlined in the Client’s Investment Policy Statement or similar document. Such restrictions could include only allowing purchases of socially conscious investments. These restrictions must be provided to GWM in writing. The Client approves the custodian to be used and the commission rates paid to the custodian. GWM does not receive any portion of the transaction fees or commissions paid by the Client to the custodian. Item 17: Voting Client Securities Proxy Votes GWM does not vote proxies on securities. Clients are expected to vote their own proxies. The Client will receive their proxies directly from the custodian of their account or from a transfer agent. When assistance on voting proxies is requested, GWM will provide recommendations to the Client. If a conflict of interest exists, it will be disclosed to the Client. Page | 18  Item 18: Financial Information Balance Sheet A balance sheet is not required to be provided because GWM does not serve as a custodian for Client funds or securities and GWM does not require prepayment of fees of more than $1200 per Client and six months or more in advance. Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients GWM has no condition that is reasonably likely to impair our ability to meet contractual commitments to our Clients. Bankruptcy Petitions during the Past Ten Years GWM has not had any bankruptcy petitions. Page | 19  Item 1 Cover Page B R O C H U R E SUPPLEMENT F O R M A D V P A R T 2 B Christopher N. Gacom, CRPC® Office Address: 301 Yamato Road Suite 3151 Boca Raton, FL 33431 Phone: 561.459.0719 Email: cgacom@greenlinewm.com Website: www.greenlinewm.com This brochure supplement provides information about Christopher N. Gacom and supplements the Greenline Wealth Management LLC brochure. You should have received a copy of that brochure. Please contact Christopher N. Gacom if you did not receive the brochure or if you have any questions about the contents of this supplement. APRIL 2, 2026 Additional information about Christopher N. Gacom (CRD #5910559) is available on the SEC’s website at www.adviserinfo.sec.gov. Page | 20  Brochure Supplement (Part 2B of Form ADV) Principal Executive Officer - Christopher N. Gacom, CRPC® • Year of birth: 1986 Item 2 - Educational Background and Business Experience Educational Background • Bowling Green State University; Bachelor of Science in Business Marketing; 2009 Professional Certifications Christopher N. Gacom has earned certifications and credentials that are required to be explained in further detail. Chartered Retirement Planning CounselorSM (CRPC®): Chartered Retirement Planning Counselor is a designation granted by the College for Financial Planning. CRPC® certification requirements: • Successfully complete the program. • Pass the final exam. • Comply with the Code of Ethics. • When you achieve your CRPC® designation, you must complete 16 hours of continuing education. • Reaffirm to abide by the Standards of Professional Conduct. • Pay a biennial renewal fee. Business Experience • Greenline Ventures LLC; Managing Member; 07/2025 - Present • Greenline Asset Management LLC, Managing Member; 09/2020 - Present • Greenline Wealth Management LLC dba Greenline Wealth Management; Member/Investment Advisor Representative; 08/2018 – Present • Greenline Insurance LLC; Insurance Agent; 08/2018 - Present • ADP Broker-Dealer, Inc.; Retirement Services District Manager; 07/2017 – 07/2018 • American Funds Distributors, Inc.; Investment Advisor Representative; 06/2013 – 06/2017 JP Morgan Chase; Banker; 08/2010 – 05/2012 • American Funds Distributors, Inc.; Registered Representative; 06/2012 – 06/2017 • American Funds; Associate Relationship Manager; 05/2016 – 06/2017 • American Funds; Area Sales Representative; 05/2012 – 05/2016 • Chase Investment Services Corp.; Registered Representative; 05/2011 – 05/2012 • • Wells Fargo Financial; Credit Manager; 12/2009 – 08/2010 • Bowling Green State University; Student; 08/2005 – 12/2009 Item 3 - Disciplinary Information Criminal or Civil Action: None to report. Administrative Proceeding: None to report. Self-Regulatory Proceeding: None to report. Page | 21  Item 4 - Other Business Activities Engaged In Christopher N. Gacom has a financial affiliated business as an insurance agent with Greenline Insurance LLC. Approximately 15% of his time is spent on this activity. He will offer Clients services from this activity. As an insurance agent, he may receive separate yet typical compensation. This practice represents a conflict of interest because it gives an incentive to recommend products based on the commission amount received. This conflict is mitigated by disclosures, procedures and the firm’s fiduciary obligation to place the best interest of the Client first and the Clients are not required to purchase any products. Clients have the option to purchase these products through another insurance agent of their choosing. Additionally, Christopher Gacom has a holding company for tax purposes. Christopher Gacom is 100% owner of Greenline Asset Management LLC and Greenline Ventures LLC. These companies to not pose a conflict of interest because no services are offered. Clients of GWM will not be solicited services for Greenline Asset Management LLC. Item 5 - Additional Compensation Christopher N. Gacom receives commissions on the insurance he sells. He does not receive any performance-based fees. Item 6 - Supervision Stephen Gagliardi is the Chief Compliance Officer of GWM. Mr. Gagliardi reviews Mr. Gacom’s work through Client account reviews and quarterly personal transaction reports, as well as face-to-face and phone interaction. Mr. Gagliardi can be reached at sgagliardi@greenlinewm.com or 561.459-0374. Page | 22  Item 1 Cover Page B R O C H U R E SUPPLEMENT F O R M A D V P A R T 2 B Stephen V. Gagliardi, CRPS® Office Address: 301 Yamato Road Suite 3151 Boca Raton, FL 33431 Phone: 561-459-0374 Email: sgagliardi@greenlinewm.com Website: www.greenlinewm.com This brochure supplement provides information about Stephen V. Gagliardi and supplements the Stephen V. Gagliardi brochure. You should have received a copy of that brochure. Please contact Stephen V. Gagliardi if you did not receive the brochure or if you have any questions about the contents of this supplement. APRIL 2, 2026 Additional information about Stephen V. Gagliardi (CRD #6528854) is available on the SEC’s website at www.adviserinfo.sec.gov. Page | 23  Brochure Supplement (Part 2B of Form ADV) Stephen V. Gagliardi, CRPS® • Year of birth: 1993 Item 2 - Educational Background and Business Experience Educational Background: • Saint Joseph’s University; Bachelor of Arts in Entrepreneurship and Marketing; 2015 Professional Certifications Stephen Gagliardi has earned certifications and credentials that are required to be explained in further detail. Chartered Retirement Plans Specialist (CRPS®): Chartered Retirement Plans Specialist is a designation granted by the College for Financial Planning. CRPS®: requirements: • Successfully complete the program encompassing pre-and-post retirement needs, asset management, estate planning and the entire retirement planning process. • Pass the final exam. • Comply with the Code of Ethics. • When you achieve your CRPS® designation, you must complete 16 hours of continuing education. • Reaffirm to abide by the Standards of Professional Conduct and comply with self- disclosure requirements. • Pay a biennial renewal fee. Business Experience: • Greenline Planning LLC; Managing Member; 09/2020 - Present • Greenline Wealth Management LLC dba Greenline Wealth Management; Member/Investment Advisor Representative; 08/2018 – Present • ADP Broker-Dealer, Inc.; Retirement Services District Manager; 07/2015 – 07/2018 • FVM Strategic Communications; Account Executive; 01/2014 – 05/2014 • Comcast; Business Analytic; 09/2012 – 12/2012 • Saint Joseph’s University; Student; 09/2011 – 06/2015 • Seton Hall Prep; Student; 09/2007 – 06/2011 Item 3 - Disciplinary Information Criminal or Civil Action: None to report. Administrative Proceeding: None to report. Self-Regulatory Proceeding: None to report. Item 4 - Other Business Activities Engaged In Stephen Gagliardi has his own holding company for tax purposes. Stephen Gagliardi is 100% owner of Greenline Planning LLC. The company does not pose a conflict of interest Page | 24  because it does not offer any services. Clients of GWM will not be solicited services for Greenline Planning LLC. Item 5 - Additional Compensation Stephen V. Gagliardi does not receive any performance-based fees. Item 6 - Supervision Since Stephen Gagliardi is the Chief Compliance Officer and Member of GWM he is responsible for all supervision and formulation and monitoring of investment advice offered to Clients. He will adhere to the policies and procedures as described in the firm’s Compliance Manual. He can be reached at sgagliardi@greenlinewm.com or 561.459-0374. Page | 25