GREENUP STREET WEALTH MANAGEMENT LLC

Greenup Street Wealth Management LLC Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Greenup Street Wealth Management LLC. If you have any questions about the contents of this brochure, please contact us at (859) 402- 1462 or by email at: greenup@keybridgecompliance.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 Greenup Street Wealth Management LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Greenup Street Wealth Management LLC’s CRD number is: 311391. 7300 W 110TH Street, Suite 700 Overland Park, KS 66210 www.greenupwealth.com Registration as an investment adviser does not imply a certain level of skill or training. Version Date: 06/30/25 i  Item 2: Material Changes The material changes in this brochure from the last annual updating amendment of Greenup Street Wealth Management LLC on 03/30/2024 are described below. • Advisor Credit Exchange ceased operations in January 2025 and all references Advisor Credit Exchange have been removed (Item 4 and Item 14). • Nerd Wallet has been added to the list of promoters that GSWML may receive client referrals from (Item 14B). • Apex Clearing Corporation and Trade-PMR, Inc. have been added to the list of custodians the Advisor may recommend (Item 12). ii  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ....................................................................................................................................... ii Item 3: Table of Contents ...................................................................................................................................... iii Item 4: Advisory Business ....................................................................................................................................... 2 Item 5: Fees and Compensation ............................................................................................................................. 5 Item 6: Performance-Based Fees and Side-By-Side Management ...................................................................... 7 Item 7: Types of Clients ........................................................................................................................................... 7 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ................................................................. 8 Item 9: Disciplinary Information .......................................................................................................................... 13 Item 10: Other Financial Industry Activities and Affiliations .......................................................................... 13 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................. 14 Item 12: Brokerage Practices ................................................................................................................................. 15 Item 13: Review of Accounts ................................................................................................................................ 17 Item 14: Client Referrals and Other Compensation ........................................................................................... 17 Item 15: Custody .................................................................................................................................................... 19 Item 16: Investment Discretion ............................................................................................................................. 19 Item 17: Voting Client Securities (Proxy Voting) ............................................................................................... 20 Item 18: Financial Information ............................................................................................................................. 20 iii  Item 4: Advisory Business A. Description of the Advisory Firm Greenup Street Wealth Management LLC d/b/a Greenup Wealth Management d/b/a Greenup Wealth (hereinafter “GSWML”) is a Limited Liability Company organized in the State of Michigan. The firm was formed in September 2020, and the principal owners are Daniel Greulich, Anthony Schmitt, Aaron Kirsch, Brandon Kraus, Alexander Fishman and Kyle Barclay. B. Types of Advisory Services Portfolio Management Services GSWML offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. GSWML creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring • • • GSWML evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. GSWML will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. GSWML seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of GSWML’s economic, investment or other financial interests. To meet its fiduciary obligations, GSWML attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, GSWML’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is GSWML’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. 2  Selection of Other Advisers GSWML may direct clients to third-party investment advisers. Before selecting other advisers for clients, GSWML will verify that all recommended advisers are properly licensed, notice filed, or exempt in the states where GSWML is recommending the adviser to clients. On-going Financial Planning On-going financial planning services may include: Initial Consultation (Free) 1. a. Assess current financial situation and discuss the financial planning process and my services. 2. Detailed meeting to go through Clients financial situation in depth and better understanding of client’s financial goals and concerns. Client Recommendation Meeting 3. a. Delivery of a financial plan including current net worth (Balance Sheet), goals, action items and more. Client walkthrough of plan and any questions. b. Recommendations. c. Included in the ongoing plan: 1. Biannual check ins with clients to assess financial plan, implementation of the plan, limitations, adjustments needed, and assess new variables in a client’s financial picture. End of Year meeting to discuss financial plan 2. 3. A new/updated financial plan annually In offering financial planning, a conflict exists between the interests of the investment adviser and the interests of the client. The client is under no obligation to act upon the investment adviser's recommendation, and, if the client elects to act on any of the recommendations, the client is under no obligation to effect the transaction through the investment adviser. This statement is required by California Code of Regulations, 10 CCR Section 260.235.2. GreenUp Protection Solutions LLC Upon review of an investor's financial status, GSWML may propose that the investor include, as part of his or her financial portfolio, one or more types of products that are not part of the investment advisory services provided by GSWML, such as insurance products. If the investor chooses to include such a product in his or her financial portfolio, GSWML recommends that the investor work closely with his or her attorney, accountant, insurance agent and other related professionals. Incorporation of the non-advisory financial product into the investor's financial plan is entirely at the client's discretion. For insurance products, GSWML’s clients may be introduced to One Resource Group, 3  through an existing partnership between One Resource Group and Greenup Protection Solutions, LLC (“GPS”), and the platform of insurance products that One Resource Group offers. GPS is a licensed insurance agency and affiliate of GreenUp. The investor is under no obligation to use GPS or One Resource Group’s services and may seek insurance advice from any licensed agent. The insurance products and fee structures available through GPS’ partnership with One Resource Group may differ from those available from other third- party insurance agents. GSWML recommends that the investor fully evaluate products and fee structures to determine which arrangements are most favorable to the investor prior to making an investment decision. GPS is entitled to receive commissions and other renumeration on the sale of insurance products. As such, GPS affects insurance transactions and receives separate, yet customary compensation. GSWML, in exchange for providing insurance product referrals to One Resource Group, may receive a portion of the commissions or other renumeration on the sale of insurance products received by GPS. Pontera GSWML provides an additional service for accounts not directly held in our custody, but where we do have discretion, and may leverage an Order Management System to implement tax-efficient asset location and opportunistic rebalancing strategies on behalf of the client. These are primarily 401(k) accounts, HSAs, and other assets GSWML does not custody. GSWML regularly reviews the available investment options in these accounts, monitor them, and rebalance and implement our strategies in the same way we do other accounts, though using different tools as necessary Services Limited to Specific Types of Investments GSWML generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds and private placements. GSWML may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions GSWML offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent GSWML from properly servicing the client account, or if the restrictions would require GSWML to deviate from its standard suite of services, GSWML reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that 4  includes management fees, transaction costs, fund expenses, and other administrative fees. GSWML does not participate in any wrap fee programs. E. Assets Under Management GSWML has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $659,228,098 $2,476,974 December 2024 Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees Total Assets Under Management Annual Fees $0 - $500,000 1.25% $500,001 - $2,000,000 1.00% $2,000,001 - $5,000,000 0.85% $5,000,001 - $10,000,000 0.70% $10,000,001 – and Up 0.45% The advisory fee is calculated using the value of the assets in the Account on the last business day of the prior billing period. Lower fees for comparable services may be available from other sources. On-going Financial Planning Fees Fixed Fees GSWML offers financial planning on both a monthly basis & flat fee basis. Standard financial planning on a monthly basis will be $250 per month. Flat fee will be $3,000 and based on the GSWML's discretion. These fees are negotiable. Clients may terminate the agreement without penalty, for full refund of GSWML’s fees, within five business days of signing the Financial Planning Agreement. Thereafter, clients 5  may terminate the Financial Planning Agreement generally upon written notice. GSWML’s fees are negotiable. The final fee schedule will be memorialized in the client’s advisory agreement. Clients may terminate the agreement without penalty for a full refund of GSWML's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract generally with 1 day's written notice. B. Payment of Fees Payment of Portfolio Management and Selection of Other Advisers Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a quarterly basis. Fees are paid in advance. Payment of On-going Financial Planning Fees Fixed Fees On- going financial planning fees are paid via ACH, Advice Pay or check. Fees are paid monthly in advance. C. Client Responsibility For Third Party Fees GSWML’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses that may be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, and other third parties such as custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual fund and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to our fee, and we shall not receive any portion of these commissions, fees, and costs. GSWML does not accept compensation for the sale of securities or other investment products including asset-based sales charges or service fees from the sale of mutual funds. D. Prepayment of Fees GSWML collects fees in advance. Refunds for fees paid in advance but not yet earned will be refunded on a prorated basis and returned within fourteen days to the client via check or return deposit back into the client’s account. For all asset-based fees paid in advance, the fee refunded will be equal to the balance of the fees collected in advance minus the daily rate* times the number of days elapsed in the billing period up to and including the day of termination. (*The daily rate is calculated by dividing the annual asset-based fee rate by 365.) 6  E. Outside Compensation For the Sale of Securities to Clients Neither GSWML nor its supervised persons accept any compensation for the sale of investment products, including asset-based sales charges or service fees from the sale of mutual funds. Rollover Recommendations As part of our investment advisory services to you, we may recommend that you withdraw the assets from your employer's retirement plan and roll the assets over to an individual retirement account ("IRA") that we will manage on your behalf. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset- based fee as set forth in the agreement you executed with our firm. This practice presents a conflict of interest because the people providing investment advice on our behalf have an incentive to recommend a rollover to you for the purpose of generating fee-based compensation rather than solely based on your needs. You are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by our firm. Many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of: 1)) Leaving the funds in your employer's (former employer's) plan; 2) moving the funds to a new employer's retirement plan; 3) cashing out and taking a taxable distribution from the plan; and/or 4) rolling the funds into an IRA rollover account. Each of these options has advantages and disadvantages and before making a change we encourage you to speak with your CPA and/or tax attorney. Our recommendations may include any of them, depending on what we feel is in your best interest. We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. As a fiduciary, we are required to document the reason(s) for why the recommendation we made is in your best interest. Item 6: Performance-Based Fees and Side-By-Side Management GSWML does not accept performance-based fees or other fees based on a share of capital gains 7  on or capital appreciation of the assets of a client. Item 7: Types of Clients GSWML generally provides advisory services to the following types of clients: Individuals High-Net-Worth Individuals Charitable Organizations Corporations or Business Entities ❖ ❖ ❖  There is no account minimum for any of GSWML’s services. Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis GSWML’s methods of analysis include Charting analysis, Cyclical analysis, Fundamental analysis, Modern portfolio theory, Quantitative analysis and Technical analysis. Charting analysis involves the use of patterns in performance charts. GSWML uses this technique to search for patterns used to help predict favorable conditions for buying and/or selling a security. Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or selling a security. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset. Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such as the character of management or the state of employee morale, such as the value of assets, the cost of capital, historical projections of sales, and so on. Technical analysis involves the analysis of past market data; primarily price and volume. Investment Strategies 8  GSWML uses long term trading, short term trading, short sales, margin transactions and options trading (excluding uncovered options; including covered options or spreading strategies). Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis 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. Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are two- fold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. 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. Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Quantitative analysis Investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. 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 9  always follow patterns and relying solely on this method may not take into account new patterns that emerge over time. Investment Strategies GSWML's use of short sales, margin transactions and options trading generally holds greater risk, and clients should be aware that there is a material risk of loss using any of those strategies. Long-term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Margin transactions use leverage that is borrowed from a brokerage firm as collateral. When losses occur, the value of the margin account may fall below the brokerage firm’s threshold thereby triggering a margin call. This may force the account holder to either allocate more funds to the account or sell assets on a shorter time frame than desired. Options transactions involve a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value, as well as the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Selection of Other Advisers: Although GSWML will seek to select only money managers who will invest clients' assets with the highest level of integrity, GSWML's selection process cannot ensure that money managers will perform as desired, and GSWML will have no control over the day-to-day operations of any of its selected money managers. GSWML would not necessarily be aware of certain activities at the underlying money manager level, including without limitation a money manager's engaging in unreported risks, investment “style drift” or even regulator breach or fraud. In monitoring and analyzing the third-party advisers, GSWML uses benchmarking analysis, assessing whether the adviser’s performance has met, exceeded, or fallen short of comparable benchmarks (e.g., Russell 2000, S&P 500, etc.), together with comparison against any stated benchmarks the adviser has set for itself. Short sales entail the possibility of infinite loss. An increase in the applicable securities’ prices will result in a loss and, over time, the market has historically trended upward. Short term trading risks include liquidity, economic stability, and inflation, in addition to the long-term trading risks listed above. Frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 10  C. Risks of Specific Securities Utilized GSWML's use of short sales, margin transactions and options trading generally holds greater risk of capital loss. Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Risks in investing in ETFs include trading risks, liquidity and shutdown risks, risks associated with a change in authorized participants and non-participation of authorized participants, risks that trading price differs from indicative net asset value (iNAV), or price fluctuation and disassociation from the index being tracked. With regard to trading risks, regular trading adds cost to your portfolio thus counteracting the low fees that one of the typical benefits of ETFs. Additionally, regular trading to beneficially “time the market” is difficult to achieve. Even paid fund managers struggle to do this every year, with the majority failing to beat the relevant indexes. With regard to liquidity and shutdown risks, not all ETFs have the same 11  level of liquidity. Since ETFs are at least as liquid as their underlying assets, trading conditions are more accurately reflected in implied liquidity rather than the average daily volume of the ETF itself. Implied liquidity is a measure of what can potentially be traded in ETFs based on its underlying assets. ETFs are subject to market volatility and the risks of their underlying securities, which may include the risks associated with investing in smaller companies, foreign securities, commodities, and fixed income investments (as applicable). Foreign securities in particular are subject to interest rate, currency exchange rate, economic, and political risks, all of which are magnified in emerging markets. ETFs that target a small universe of securities, such as a specific region or market sector, are generally subject to greater market volatility, as well as to the specific risks associated with that sector, region, or other focus. ETFs that use derivatives, leverage, or complex investment strategies are subject to additional risks. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. The return of an index ETF is usually different from that of the index it tracks because of fees, expenses, and tracking error. An ETF may trade at a premium or discount to its net asset value (NAV) (or indicative value in the case of exchange-traded notes). The degree of liquidity can vary significantly from one ETF to another and losses may be magnified if no liquid market exists for the ETF’s shares when attempting to sell them. Each ETF has a unique risk profile, detailed in its prospectus, offering circular, or similar material, which should be considered carefully when making investment decisions. Real estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Private placements carry a substantial risk as they are subject to less regulation than are publicly offered securities, the market to resell these assets under applicable securities laws may be illiquid, due to restrictions, and the liquidation may be taken at a substantial discount to the underlying value or result in the entire loss of the value of such assets. Venture capital funds invest in start-up companies at an early stage of development in the interest of generating a return through an eventual realization event; the risk is high as a result of the uncertainty involved at that stage of development. Commodities are tangible assets used to manufacture and produce goods or services. Commodity prices are affected by different risk factors, such as disease, storage capacity, supply, demand, delivery constraints and weather. Because of those risk factors, even a 12  well-diversified investment in commodities can be uncertain. Options are contracts to purchase a security at a given price, risking that an option may expire out of the money resulting in minimal or no value. An uncovered option is a type of options contract that is not backed by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option positions entail buying and selling multiple options on the same underlying security, but with different strike prices or expiration dates, which helps limit the risk of other option trading strategies. Option transactions also involve risks including but not limited to economic risk, market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate risk. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither GSWML nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. 13  B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither GSWML nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Aaron Gideon Kirsch is a licensed insurance agent through Greenup Protection Solutions, LLC (“GPS”), a licensed insurance company and affiliate of GSWML. GSWML’s clients may be introduced to One Resource Group, through an existing partnership between One Resource Group and Greenup Protection Solutions (“GPS”), and the platform of insurance products that One Resource Group offers. The insurance products and fee structures available from One Resource Group may differ from those available from other third- party insurance agents. GSWML recommends that the investor fully evaluate products and fee structures to determine which arrangements are most favorable to the investor prior to making an investment decision. Clients should be aware that these services pay a commission to One Resource Group, and the commission is shared with GPS. This creates a potential conflict of interest, as commissionable products can conflict with the fiduciary duties of a registered investment advisers. Greenup Street Wealth Management LLC always acts in the best interest of the client; including in the sale of commissionable products through One Resource Group. Clients are in no way required to implement the plan through any representative of One Resource Group in their capacity as a licensed insurance agent. GSWML, in exchange for providing insurance product referrals to GPS and One Resource Group, receives a portion of the commissions or other renumeration on the sale of insurance products. Alexander Fishman is a board member of Junior Achievement of Greater Kansas City. Anthony Michael Schmitt and Alexander Fishman act as COO and President/CEO of Advisor Tax Resource (ATR), respectively. ATR may provide tax guidance to GSWML Wealth Managers and complete tax returns for GSWML clients. Neither Mr. Schmitt nor Mr. Fishman receive compensation from ATR and GSWML does not receive compensation for these referrals. All material conflicts of interest under California Code of Regulations Section 260.238(k) are disclosed regarding the investment adviser, its representatives or any of its employees, which could be reasonable expected to impair the rendering of unbiased and objective advice. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections 14  GSWML may engage third-party investment managers as part of the investment management process who offer specialized investment services or expertise in certain facets of investing, including direct indexing. Clients will pay GSWML its standard fee in addition to the standard fee for the advisers to which it directs those clients. The fees will not exceed any limit imposed by any regulatory agency. GSWML does not receive any additional compensation for the selection of a third-party investment manager. GSWML will always act in the best interests of the client, including when determining which third party investment adviser to recommend to clients. GSWML will ensure that all recommended advisers are exempt, licensed or notice filed in the states in which GSWML is recommending them to clients. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics GSWML has a written Code of Ethics that covers the following areas: Participation or Interest in Client Transactions, Personal Trading, Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. GSWML's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests GSWML does not recommend that clients buy or sell any security in which a related person to GSWML or GSWML has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of GSWML may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of GSWML to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. GSWML will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities 15  From time to time, representatives of GSWML may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of GSWML to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, GSWML will never engage in trading that operates to the client’s disadvantage if representatives of GSWML buy or sell securities at or around the same time as clients. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers the market expertise and research access provided by Custodians/broker-dealers will be recommended based on GSWML’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and GSWML may also consider the broker- dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in GSWML's research efforts. GSWML will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker-dealer/custodian. GSWML recommends Fidelity Brokerage Services LLC, Schwab Institutional, a division of Charles Schwab & Co., Inc., Apex Clearing Corporation, and Trade-PMR, Inc. 1. Research and Other Soft-Dollar Benefits GSWML does not receive products or services other than execution (“soft dollar benefits”) from a broker-dealer or third-party for generating commissions, but does receive additional economic benefits described in Item 14. 2. Brokerage for Client Referrals GSWML receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use GSWML may permit clients to direct it to execute transactions through a specified broker-dealer. If a client directs brokerage, then the client will be required to acknowledge in writing that the client’s direction with respect to the use of brokers supersedes any authority granted to GSWML to select brokers; this direction may result in higher commissions, which may result in a disparity between free and 16  directed accounts; the client may be unable to participate in block trades (unless GSWML is able to engage in “step outs”); and trades for the client and other directed accounts may be executed after trades for free accounts, which may result in less favorable prices, particularly for illiquid securities or during volatile market conditions. Not all investment advisers allow their clients to direct brokerage. B. Aggregating (Block) Trading for Multiple Client Accounts If GSWML buys or sells the same securities on behalf of more than one client, then it may (but would be under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients in order to seek more favorable prices, lower brokerage commissions, or more efficient execution. In such case, GSWML would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. GSWML would determine the appropriate number of shares and select the appropriate brokers consistent with its duty to seek best execution, except for those accounts with specific brokerage direction (if any). Mutual Fund Share Class Selection Mutual funds generally offer multiple share classes available for investment based upon certain eligibility and/or purchase requirements. For instance, in addition to retail share classes (typically referred to as class A, class B and class C shares), funds may also offer institutional share classes or other share classes that are specifically designed for purchase by investors who meet certain specified eligibility criteria, including, for example, whether an account meets certain minimum dollar amount. Institutional share classes usually have a lower expense ratio than other share classes. When recommending investments in mutual funds, it is our policy to review and consider available share classes. Our policy is to select the most appropriate share classes based on various factors including but not limited to: minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability and other factors. When considering all the appropriate factors, we can select a share class other than the ‘lowest cost’ share class. In order to select the most appropriate share class, we consider retail, institutional or other share classes of the same mutual fund. Regardless of such considerations, clients should not assume that they will be invested in the share class with the lowest possible expense ratio. Clients should ask their adviser whether a lower cost share class is available instead of those selected by the Firm. GSWML periodically reviews the mutual funds held in client accounts to select the most appropriate share classes in light of its duty to obtain best execution. Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews 17  Each account receives at a minimum an annual review by the IARs on the client's advisory team. In most cases, accounts are reviewed more frequently through various means, including telephone calls, in-person meetings, overall strategy reviews, and/or the review of monthly and quarterly statements. Reviews are based on objectives and parameters established by clients, which are generally memorialized through their individual advisory agreements or other suitability and investment objectives. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material markets, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). C. Content and Frequency of Regular Reports Provided to Clients Each client of GSWML's advisory services provided on an ongoing basis will receive a quarterly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. GSWML will also provide at least quarterly a separate written statement to the client. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) Charles Schwab & Co., Inc. Advisor Services provides GSWML with access to Charles Schwab & Co., Inc. Advisor Services’ institutional trading and custody services, which are typically not available to Charles Schwab & Co., Inc. Advisor Services retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Charles Schwab & Co., Inc. Advisor Services. Charles Schwab & Co., Inc. Advisor Services includes brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For GSWML client accounts maintained in its custody, Charles Schwab & Co., Inc. Advisor Services generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Charles Schwab & Co., Inc. Advisor Services or that settle into Charles Schwab & Co., Inc. Advisor Services accounts. 18  Charles Schwab & Co., Inc. Advisor Services also makes available to GSWML other products and services that benefit GSWML but may not benefit its clients’ accounts. These benefits may include national, regional or GSWML specific educational events organized and/or sponsored by Charles Schwab & Co., Inc. Advisor Services. Other potential benefits may include occasional business entertainment of personnel of GSWML by Charles Schwab & Co., Inc. Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist GSWML in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of GSWML’s fees from its clients’ accounts (if applicable), and assist with back- office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of GSWML’s accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to GSWML other services intended to help GSWML manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, and human capital consultants, insurance and marketing. In addition, Charles Schwab & Co., Inc. Advisor Services may make available, arrange and/or pay vendors for these types of services rendered to GSWML by independent third parties. Charles Schwab & Co., Inc. Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to GSWML. GSWML is independently owned and operated and not affiliated with Charles Schwab & Co., Inc. Advisor Services. Greenup Protection Solutions GSWML, in exchange for providing insurance product referrals to One Resource Group, may receive a portion of the commissions or other renumeration on the sale of insurance products received by GreenUp Protection Solutions, LLC. (“GPS”). B. Compensation to Non – Advisory Personnel for Client Referrals Promoter and Lead Generation Firms GSWML engages independent promoters to provide client referrals. If a client is referred to us by a promoter, this practice is disclosed to the client in writing by the promotor and GSWML pays the promoter out of its own funds—specifically, GSWML generally pays the promoter a portion of the advisory fees earned for managing the capital of the client or investor that was referred. The use of promoters is strictly regulated under applicable federal and state law. GSWML’s policy is to fully comply with the requirements of Rule 206(4)-3, under the Investment Advisers Act of 1940, as amended, and similar state rules, as applicable. 19  GSWML may receive client referrals from Aaron Wealth Advisors LLC, The Pickle Pros, LLC (also doing business as Money Pickle), Naviter Wealth, LLC, Nerd Wallet, Rainbook Advisors, LLC and Zoe Financial, Inc (collectively, “GSWML’s Promoters”). GSWML’s Promoters are independent of and unaffiliated with the Advisor and its employees. GSWML’s Promoters do not supervise GSWML and have no responsibility for GSWML’s management of client portfolios or GSWML’s other advice or services. GSWML pays GSWML’s Promoters an on-going fee for each successful client referral. This fee is usually a percentage of the advisory fee that the client pays to GSWML (“Promoter Fee”). GSWML will not charge clients referred through its relationships with GSWML’s Promoters any fees or costs higher than its standard fee schedule offered to its clients. For information regarding additional or other fees paid directly or indirectly to GSWML’s Promoters, please contact us at greenup@keybridgecompliance.com. GSWML’s Promoter relationships will be fully disclosed to each Client to the extent required by applicable law. GSWML will ensure each promoter is exempt, notice filed or properly registered in all appropriate jurisdictions. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, GSWML will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. GSWML will also be deemed to have custody over any accounts where clients have established standing letters of authorization (“SLOAs”) with any third parties. Clients will receive all account statements from the broker-dealer, bank or other qualified custodian at least quarterly, and should carefully review those statements for accuracy. Clients will also receive statements from GSWML and are urged to compare the statements they receive from the qualified custodian with those they receive from GSWML. Item 16: Investment Discretion GSWML provides discretionary and non-discretionary investment advisory services to clients. The advisory contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, GSWML generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. Clients with discretionary accounts will execute a limited power of attorney to evidence discretionary authority. Clients may, but typically do not, impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. Where GSWML does not have discretionary authority to place trade orders, GSWML will secure client permission prior to effecting securities transactions for the client’s account. 20  Item 17: Voting Client Securities (Proxy Voting) GSWML will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information A. Balance Sheet GSWML neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither GSWML nor its management has any financial condition that is likely to reasonably impair GSWML’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years GSWML has not been the subject of a bankruptcy petition in the last ten years. 21  Greenup Street Wealth Management LLC Kansas Addendum to Firm Brochure Disclosure for clients and prospective clients residing in Kansas: Please be advised that the investment advisory firm has professional liability insurance coverage for its investment advisory services. If applicable, a copy of the insurance agreement for the firm’s professional liability insurance coverage will be provided to the client upon request. 22