Guided Capital Wealth Management, LLC

Guided Capital Wealth Management, LLC Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Guided Capital Wealth Management, LLC. If you have any questions about the contents of this brochure, please contact us at (832) 975- 0710 or by email at: info@guidedcapitalwealth.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 Guided Capital Wealth Management, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Guided Capital Wealth Management, LLC’s CRD number is: 310056. 24 Greenway Plaza, Suite 1203 Houston, TX 77046 (832) 975-0710 info@guidedcapitalwealth.com https://www.guidedcapitalwealth.com Registration as an investment adviser does not imply a certain level of skill or training. Version Date: 03/11/2026 i  Item 2: Material Changes There have been no material changes made to this disclosure brochure since the last annual amendment filing on March 3, 2025. 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 ............................................................................................................................................................................................. 4 Item 5: Fees and Compensation ................................................................................................................................................................................... 7 Item 6: Performance-Based Fees and Side-By-Side Management .......................................................................................................................... 10 Item 7: Types of Clients ............................................................................................................................................................................................... 11 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ..................................................................................................................... 11 Item 9: Disciplinary Information ................................................................................................................................................................................ 15 Item 10: Other Financial Industry Activities and Affiliations ................................................................................................................................ 15 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ....................................................................... 16 Item 12: Brokerage Practices ....................................................................................................................................................................................... 17 Item 13: Review of Accounts ...................................................................................................................................................................................... 18 Item 14: Client Referrals and Other Compensation ................................................................................................................................................. 19 Item 15: Custody .......................................................................................................................................................................................................... 21 Item 16: Investment Discretion ................................................................................................................................................................................... 21 Item 17: Voting Client Securities (Proxy Voting) ..................................................................................................................................................... 22 Item 18: Financial Information ................................................................................................................................................................................... 22 iii  Item 4: Advisory Business A. Description of the Advisory Firm Guided Capital Wealth Management, LLC (hereinafter “GCWM”) is a Limited Liability Company organized in the State of Texas. The firm was formed in November 2018, and the principal owners and managing members are Kyle Richard Louvar and Nicole Christine Louvar. Nicole Christine Louvar is the chief compliance officer. B. Types of Advisory Services Portfolio Management Services GCWM offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. GCWM 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 are only offered through the wrap. Portfolio management services include, but are not limited to, the following: • • • Investment strategy Asset allocation Assessment of Risk tolerance • • • Personal investment policy Asset selection Regular portfolio monitoring GCWM evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. GCWM 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. GCWM seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of GCWM’s economic, investment or other financial interests. To meet its fiduciary obligations, GCWM attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, GCWM’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 GCWM’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. 4  Pension Consulting Services GCWM offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to: • • • identifying investment objectives and restrictions providing guidance on various assets classes and investment options recommending money managers to manage plan assets in ways designed to achieve objectives • monitoring performance of money managers and investment options and making recommendations for changes • recommending other service providers, such as custodians, administrators and broker-dealers • creating a written pension consulting plan These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Investment planning involves working with clients to make sure their investments match their respective risk tolerance and goals. Tax concerns are addressed by working with the client to determine and compare effective tax rates for income, capital gains and other earnings or investments, then attempting to allocate the client’s resources accordingly. Life insurance planning entails reviewing the life insurance and/or disability insurance needs of the client, together with any applicable dependents, spouse or other relatives, and assessing appropriate coverage for these individuals. College planning entails helping clients save for higher education, whether for the client or his/her children or other dependents, in the ideal manner to suit the client’s overall financial goals and means. Financial planning to address retirement entails making sure clients are financially equipped for retirement in light of the client’s anticipated income and expenses, investments, and other assets. Debt/credit planning consists of breaking down client budgets and aiding clients in decision-making as to current debt, anticipated significant expenses and potential debt, and avoiding excessive debt. On-going Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. 5  On-going financial planning services may include: 1. Initial Consultation (Free) a. Assess current financial situation and discuss the financial planning process and my services Client Recommendation Meeting 2. Detailed meeting to go through Clients financial situation in depth and better understanding of client’s financial goals and concerns 3. a. Delivery of a financial plan including current net worth (Balance Sheet), goals, action items and more. b. c. Recommendations Client walkthrough of plan and any questions Included in the ongoing plan: 1. There is at the least a minimum annual check in with clients to assess financial plan, implementation of the plan, limitations, adjustments needed, and assess new variables in a client’s financial picture. 2. Annual meeting to discuss financial plan 3. A new/updated financial plan annually Participant Account Management (Discretionary) The Advisor may use third-party platforms to access, aggregate, or manage certain client accounts that are held away from the Advisor’s primary custodians, such as employer- sponsored retirement plans or other externally maintained accounts. These platforms allow clients to grant the Advisor authorized access to account information and, where permitted, limited account management capabilities. Access to such accounts is provided solely at the client’s direction and subject to the permissions granted by the client through the third-party platform. Recommendations to have assets managed through a third-party platform pose a conflict between the interests of the Advisor and the interests of the Client. Assets managed through a third- party platform increases the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to have the Advisor manage held-away assets by the Advisor. Services Limited to Specific Types of Investments GCWM generally limits its investment advice to mutual funds, fixed income securities, insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal sectors) and treasury inflation protected/inflation linked bonds. 6  C. Client Tailored Services and Client Imposed Restrictions GCWM 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 GCWM from properly servicing the client account, or if the restrictions would require GCWM to deviate from its standard suite of services, GCWM reserves the right to end the relationship. D. Wrap Fee Programs GCWM acts as portfolio manager for a wrap fee program, which is an investment program where the client pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. E. Assets Under Management GCWM has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 249,186,592.00 $ 0.00 December 2025 Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees Total Assets Under Management Annual Fees $1 - $999,999 1.50% $1,000,000 - $1,999,999 1.25% $2,000,000 - $2,999,999 1.00% $3,000,000 - AND UP Negotiable GCWM uses the value of the account as of the last business day of the billing period monthly in arrears direct deduction from the clients account (please see Item 15 about 7  direct deduction) after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. GCWM does not charge clients higher advisory fees based on their trading activity, but clients should be aware that GCWM may have an incentive to limit trading activities in client account(s) because GCWM is charged for executed trades. These fees are generally negotiable and the final fee schedule will be memorialized in the client’s advisory agreement. Clients may terminate the agreement without fee or penalty five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract immediately upon written notice. Any unpaid earned fees will be due in payable to GCWM upon termination. Pension Consulting Services Fees Asset-Based Fees for Pension Consulting Total Assets Under Management Annual Fee All Assets 0.40% GCWM uses the value of the account as of the last business day of the billing period, monthly in arrears direct deduction from the clients account (please see Item 15 about direct deduction) after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. These fees are generally negotiable and 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 GCWM's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the pension consulting agreement immediately upon written notice. GCWM uses an average of the daily balance in the client’s account throughout the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. Financial Planning Fees Fixed Fees The negotiated fixed rate for creating client financial plans is between $1,200 and $20,000. 8  On-going Financial Planning Fees Fixed Fees The negotiated fixed rate for on-going financial planning services is between $1,200 and $20,000. Fees are paid monthly arrears. Clients may terminate the agreement without penalty, for full refund of GCWM’s fees, within five business days of signing the Financial Planning Agreement. Thereafter, clients may terminate the Financial Planning Agreement generally upon written notice. Clients upon termination the firm is due any unpaid fees based on date of termination. B. Payment of Fees Payment of Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a monthly basis. Fees are paid in arrears. Please see Item 15 about direct deduction. Monthly fees are for a minimal one year plan with a client. Payment of Pension Consulting Fees Asset-based pension consulting fees are withdrawn directly from the client's accounts with client's written authorization on a quarterly basis. Fees are paid in arrears. Payment of Financial Planning Fees Financial planning fees are paid via wire or check. Monthly fees are for a minimal one- year plan with a client. Fixed financial planning fees are paid 100% in advance, but never more than six months in advance. Payment of On-going Financial Planning Fees Fixed Fees On- going Financial planning fees are paid via check. Fees are paid monthly in arrears. 9  C. Client Responsibility For Third Party Fees This brochure describes GCWM’s non-wrap fee advisory services; clients utilizing GCWM’s wrap fee portfolio management should see the separate Wrap Fee Program Brochure for additional details regarding third party fees. Client accounts not participating in the wrap fee program are responsible for the payment of all third party fees (i.e., custodian fees, commissions, brokerage fees, internal mutual fund fees for management and administration, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by GCWM. Please see Item 12 of this brochure regarding broker/custodian. Schwab has eliminated commissions for online trades of equities, ETFs and options (subject to $0.65 per contract fee). This means that, in most cases, when we buy and sell these types of securities, we will not have to pay any commissions to Schwab. We encourage you to review Schwab’s pricing to compare the total costs of entering into a wrap fee arrangement versus a non-wrap fee arrangement. If you choose to enter into a wrap fee arrangement, your total cost to invest could exceed the cost of paying for brokerage and advisory services separately. To see what you would pay for transactions in a non-wrap account please refer to Schwab’s most recent pricing schedules available at schwab.com/aspricingguide. D. Prepayment of Fees GCWM collects fees for financial planning 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. Fixed fees that are collected in advance will be refunded based on the prorated amount of work completed at the point of termination. E. Outside Compensation For the Sale of Securities to Clients Neither GCWM 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. Item 6: Performance-Based Fees and Side-By-Side Management GCWM does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Therefore, GCWM does not engage in side by side management. 10  Item 7: Types of Clients GCWM generally provides advisory services to the following types of clients: ❖ ❖ ❖ ❖ Individuals High-Net-Worth Individuals Pension and Profit Sharing Plans Corporations or Business Entities There is no account minimum for any of GCWM’s services. Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis GCWM’s methods of analysis include Charting analysis, Cyclical analysis, Fundamental analysis and Technical analysis. Charting analysis involves the use of patterns in performance charts. GCWM 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. Technical analysis involves the analysis of past market data; primarily price and volume. Investment Strategies GCWM offers investment strategy models based on each clients’ risk tolerance. GCWM’s risk tolerance models available include: Conservative, Moderately Conservative, Moderate, Moderately Aggressive and Aggressive. The GCWM models seek to combine both index and actively managed exchange-traded funds (ETFs) and/or individual stocks, representing various asset classes and sectors, within a disciplined allocation methodology based on risk tolerance and asset allocation objectives. The portfolio construction process is a strategic allocation among equities, fixed income, and cash. 11  GCWM may use, at the request of the client, margin transactions and options trading, provided the client’s investment objectives and risk tolerance align with the request. 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. 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. Investment Strategies GCWM's uses transactions and 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. 12  Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized GCWM's use 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 13  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 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) and in each purchased at a premium may be sold as a discount (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. Annuities are a retirement product for those who may have the ability to pay a premium now and want to guarantee they receive certain monthly payments or a return on investment later in the future. Annuities are contracts issued by a life insurance company designed to meet requirement or other long-term goals. An annuity is not a life insurance policy. Variable annuities are designed to be long-term investments, to meet retirement and other long-range goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes and insurance company charges may apply if you withdraw your money early. Variable annuities also involve investment risks, just as mutual funds do. 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. 14  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 GCWM nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither GCWM 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 Neither GCWM nor its representatives have any material relationships to this advisory business that would present a possible conflict of interest. 15  D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections GCWM does not utilize nor select third-party investment advisers. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics GCWM has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. GCWM's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests GCWM does not recommend that clients buy or sell any security in which a related person to GCWM or GCWM has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of GCWM may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of GCWM 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, GCWM will never engage in trading that front runs or operates to the client’s disadvantage if representatives of GCWM buy or sell securities at or around the same time as clients. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of GCWM may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of GCWM 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, GCWM will never engage in trading that front runs or operates to the client’s disadvantage if representatives of GCWM buy or sell securities at or around the same time as clients. 16  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 GCWM’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 GCWM 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 GCWM's research efforts. GCWM has the discretion to recommend Charles Schwab & Co., Inc. Advisor Services (CRD# 5393) as the custodian/broker- dealer for client accounts. 1. Research and Other Soft-Dollar Benefits While GCWM has no formal soft dollars program in which soft dollars are used to pay for third party services, GCWM may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft dollar benefits”). GCWM may enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and GCWM does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. GCWM benefits by not having to produce or pay for the research, products or services, and GCWM will have an incentive to recommend a broker-dealer based on receiving research or services. Clients should be aware that GCWM’s acceptance of soft dollar benefits may result in higher commissions charged to the client. 2. Brokerage for Client Referrals GCWM 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 GCWM will require clients to use a specific broker-dealer to execute transactions. Not all advisers require clients to use a particular broker-dealer. 17  B. Aggregating (Block) Trading for Multiple Client Accounts If GCWM 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, GCWM 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. GCWM would determine the appropriate number of shares and select the appropriate custodian consistent with its custodian direction (if any). As a general policy, and if GCWM believes it is appropriate under the circumstances, securities orders placed for the same security on the same day may be combined (or “blocked” or “aggregated”) with the objective of receiving the best overall blend of pricing and execution. The subsequent allocations among such accounts will be effectuated on a pro rata basis, based on the relative value of the accounts. GCWM may also break a block order into multiple blocks if we determine multiple order blocks will receive a better overall blend of pricing and execution. In such cases the subsequent allocations among accounts will be effectuated on an average price basis (such that each account receives the same price based on the average price across blocks). Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts under GCWM’s management are reviewed at least quarterly by Kyle R Louvar, CEO, with regard to clients’ respective investment policies and risk tolerance levels. All accounts at GCWM are assigned to this reviewer. Kyle R Louvar will review accounts with clients at least annually. All financial planning accounts are reviewed upon financial plan creation and plan delivery by Kyle R Louvar, CEO. Financial planning clients are provided online access to their financial plan through our financial planning software, eMoney. After the presentation of the plan, there are no further reports. For information about ongoing services see Item 4. 18  B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). With respect to financial plans, GCWM’s services will generally conclude upon delivery of the financial plan. C. Content and Frequency of Regular Reports Provided to Clients Each client of GCWM's advisory services provided on an ongoing basis will receive a monthly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written statement will come from the custodian. GCWM does not provide account statements to clients in addition to those provided by the custodian. Each financial planning client will receive the financial plan upon completion. Each client will receive the financial plan through a software provider. Clients have access to this information through the firm’s portal. 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) • Products & Services Available to Us From Schwab Schwab Advisor Services is Schwab’s business serving independent investment advisory firms like ours. They provide us and our clients with access to its institutional brokerage – trading, custody, reporting and related services – many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts while others help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis, at no charge to advisors. • Services that Benefit Client Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit clients or their account(s). 19  • Services that May Not Directly Benefit Clients Schwab also makes available to us other products and services that benefit us but may not directly benefit the client or their account(s). These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or some substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • provides access to client account data (such as duplicate trade confirmations and • account statements); facilitates trade execution and allocate aggregated trade orders for multiple client accounts; facilitates payment of our fees from our clients’ accounts; and • provides pricing and other market data; • • assists with back-office functions, recordkeeping and client reporting. Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: technology, compliance, legal, and business consulting; • educational conferences and events • • publications and conferences on practice management and business succession; and • access to employee benefits providers, human capital consultants and insurance providers. Schwab may provide some of these services itself. In other cases, it will arrange for third- party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Irrespective of direct or indirect benefits to our client through Schwab, we strive to enhance the client’s experience, help reach their goals and put their interests before that of our firm or its associated persons. B. Compensation to Non – Advisory Personnel for Client Referrals GCWM does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. 20  Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, GCWM will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. GCWM does not have physical custody of client funds or securities. However, when advisory fees are deducted directly from client accounts at client's custodian, GCWM will be deemed to have limited custody of a client's assets. For fees deducted directly from client accounts, in states that require it, GCWM will: (A) Possess written authorization from the client to deduct advisory fees from an account held by a qualified custodian. (B) Utilize a custodian that sends at least quarterly statements reflecting all additions and deductions, including the amount of advisory fees. (C) Send the qualified custodian written notice of the amount of the fee to be deducted and send the client a written invoice upon or prior to fee deduction itemizing the fee, including the formula used to calculate the fee, the time period covered by the fee, and the amount of assets under management on which the fee was based. Clients will receive all account statements from the custodian and billing invoices from GCWM that are required in each jurisdiction, and they should carefully review those statements for accuracy. Item 16: Investment Discretion GCWM provides 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, GCWM 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 may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent GCWM from properly servicing the client account, or if the restrictions would require GCWM to deviate from its standard suite of services, GCWM reserves the right to end the relationship. 21  Item 17: Voting Client Securities (Proxy Voting) GCWM 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 may direct all proxy questions to the issuer of to CGWM. Item 18: Financial Information A. Balance Sheet GCWM 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 GCWM nor its management has any financial condition that is likely to reasonably impair GCWM’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years GCWM has not been the subject of a bankruptcy petition in the last ten years. 22 

Guided Capital Wealth Management, LLC Wrap Fee Program Brochure This wrap fee program brochure provides information about the qualifications and business practices of Guided Capital Wealth Management, LLC. If you have any questions about the contents of this brochure, please contact us at (832) 975-0710 or by email at: info@guidedcapitalwealth.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 Guided Capital Wealth Management, LLC is also available on the SEC’s website at https://www.guidedcapitalwealth.com. Guided Capital Wealth Management, LLC’s CRD number is:310056. 24 Greenway Plaza, Suite 1203 Houston, TX 77046 (832) 975-0710 https://www.guidedcapitalwealth.com info@guidedcapitalwealth.com Registration as an investment adviser does not imply a certain level of skill or training. Version Date: 03/11/2026  Item 2: Material Changes There have been no material changes made to this to this Wrap Fee Program Brochure since the last filing on March 3, 2025. 1  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ........................................................................................................................... 1 Item 3: Table of Contents ........................................................................................................................... 2 Item 4: Advisory Business .......................................................................................................................... 3 Item 5: Types of Clients .............................................................................................................................. 4 Item 6: Portfolio Manager Selection and Evaluation .............................................................................. 5 Item 7: Client Information Provided to Portfolio Managers ............................................................... 10 Item 8: Client Contact with Portfolio Managers ................................................................................... 10 Item 9: Additional Information ............................................................................................................... 11 2  Item 4: Advisory Business A. Description of the Advisory Firm Guided Capital Wealth Management, LLC (hereinafter “GCWM”) provides portfolio management to clients under this wrap fee program as sponsor and portfolio manager. Total Assets Under Management Annual Fees All Assets Up to 1.50% These fees are generally negotiable and the final fee schedule will be memorialized in the client’s advisory agreement. GCWM does not charge clients higher advisory fees based on their trading activity, but clients should be aware that GCWM may have an incentive to limit trading activities in client account(s) because GCWM is charged for executed trades. Fees will be invoiced to the custodian for the management fee, and direct and authorize the custodian to deduct the amount stated from one or more of your Accounts., on a monthly basis in arrears. Fees are paid in arrears. GCWM uses the value of the account as of the last business day of the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. Clients may terminate the agreement without fee or penalty, within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract immediately upon written notice. Any unpaid earned fees will be due in payable to GCWM upon termination. B. Contribution Cost Factors The program may cost the client more or less than purchasing such services separately. There are several factors that bear upon the relative cost of the program, including the trading activity in the client’s account, the adviser’s ability to aggregate trades, and the cost of the services if provided separately (which in turn depends on the prices and specific services offered by different providers). C. Additional Fees GCWM will wrap third party fees (i.e., custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.) for wrap fee portfolio management accounts. GCWM will charge clients one fee, and pay all transaction fees using the fee collected from the client. Accounts participating in the wrap fee program are not charged higher advisory fees based on 3  trading activity. Schwab has eliminated commissions for online trades of equities, ETFs and options (subject to $0.65 per contract fee). This means that, in most cases, when we buy and sell these types of securities, we will not have to pay any commissions to Schwab. We encourage you to review Schwab’s pricing to compare the total costs of entering into a wrap fee arrangement versus a non-wrap fee arrangement. If you choose to enter into a wrap fee arrangement, your total cost to invest could exceed the cost of paying for brokerage and advisory services separately. To see what you would pay for transactions in a non-wrap account please refer to Schwab’s most recent pricing schedules available at schwab.com/aspricingguide. You may pay custodial fees, charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses), mark-ups and mark-downs, spreads paid to market makers, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. These fees are not included within the wrap-fee you are charged by our firm. Certain other fees are not included in the wrap fee and are paid for separately by the client. These include, but are not limited to, margin costs, charges imposed directly by a mutual fund or exchange traded fund, fees associated with “step out” transactions if the account uses different custodians or broker-dealers, 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. D. Compensation of Client Participation Neither GCWM, nor any representatives of GCWM receive any additional compensation beyond advisory fees for the participation of client’s in the wrap fee program. However, compensation received may be more than what would have been received if client paid separately for investment advice, brokerage, and other services. Therefore, GCWM may have a financial incentive to recommend the wrap fee program to clients. Item 5: Types of Clients GCWM generally offers advisory services to the following types of clients: ❖ Individuals ❖ High-Net-Worth Individuals ❖ Pension and Profit Sharing Plans ❖ Corporations or Business Entities There is no account minimum for any of GCWM’s services. 4  Item 6: Portfolio Manager Selection and Evaluation A. Selecting/Reviewing Portfolio Managers GCWM will not select outside portfolio managers for management of this wrap fee program. GCWM will be the sole portfolio manager for this wrap fee program. GCWM will use industry standards to calculate portfolio manager performance. GCWM reviews the performance information to determine and verify its accuracy and compliance with presentation standards. The performance information is annually and is reviewed by GCWM. B. Related Persons GCWM and its personnel serve as the portfolio managers for all wrap fee program accounts. This is a conflict of interest in that no outside adviser assesses GCWM’s management of the wrap fee program. However, GCWM addresses this conflict by acting in its clients’ best interest consistent with its fiduciary duty as sponsor and portfolio manager of the wrap fee program. C. Advisory Business GCWM offers ongoing wrap fee portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. GCWM creates an Investment Policy Statement for each client, which outlines the client’s current financial situation (including but not limited to: income, expenses, goals, objectives, time horizon, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: • • • Determine investment strategy Asset allocation Assessment of risk tolerance • • • Personal investment policy Asset selection Regular portfolio monitoring GCWM evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. GCWM 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. 5  Portfolio management accounts participating in the wrap fee program will not have to pay for transaction or trading fees. GCWM will charge clients one fee, and pay transaction fees using the advisory fee collected from the client. Certain other fees are not included in the wrap fee and are paid for separately by the client. These include, but are not limited to, margin costs, charges imposed directly by a mutual fund or exchange traded fund, 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. Accounts participating in the wrap fee program are not charged higher advisory fees based on trading activity. Services Limited to Specific Types of Investments GCWM generally limits its investment advice to mutual funds, equities, fixed income securities, ETFs, ETFs in the gold and precious metal sectors, and insurance products including annuities. GCWM may use other securities as well to help diversify a portfolio when applicable. Client Tailored Services and Client Imposed Restrictions GCWM offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client’s current situation (including but not limited to: income, expenses, goals, objectives, time horizon, tax levels, and risk tolerance levels). Clients are permitted to impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. Wrap Fee Programs As discussed herein, GCWM sponsors and acts as portfolio manager for this wrap fee program. GCWM manages the investments in the wrap fee program, but does not manage those wrap fee accounts any differently than it would manage non-wrap fee accounts the fees paid to the wrap account program will be given to GCWM as a management fee. Amounts Under Management GCWM has the following assets under management: Discretionary Amounts: Non-Discretionary Amounts: Date Calculated: $ 0.00 December 2025 $ 249,186,592.00 Performance-Based Fees and Side-By-Side Management GCWM does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. 6  Clients paying a performance-based fee should be aware that investment advisers have an incentive to invest in riskier investments when paid a performance-based fee due to the higher risk/higher reward attributes. Methods of Analysis and Investment Strategies Methods of Analysis GCWM’s methods of analysis include charting analysis, fundamental analysis, technical analysis and cyclical analysis. Charting analysis involves the use of patterns in performance charts. GCWM uses this technique to search for patterns used to help predict 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. Technical analysis involves the analysis of past market data; primarily price and volume. Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or selling a security. Investment Strategies GCWM uses long term trading, transactions and options trading (including covered options or spreading strategies). Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 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. 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. 7  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. 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. Investment Strategies GCWM’s use of transactions and these transactions generally holds greater risk, and clients should be aware that there is a material risk of loss using any of those strategies. Long term investing 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. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Risks of Specific Securities Utilized investment types GCWM’s use of transactions and these transactions generally holds greater risk of capital loss. Clients should be aware that there is a material risk of loss using any investment listed below (leaving aside Treasury Inflation strategy. The Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. 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 8  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. Because ETFs use "authorized participants" (APs) as agents to facilitate creations or redemptions (primary market), there is a risk that an AP decides to no longer participate for a particular ETF; however, that risk is mitigated by the fact that other APs can step in to fill the vacancy of the withdrawing AP [an ETF typically has multiple APs] and ETF transactions predominantly take place in the secondary market without need for an AP. Like other liquid securities, ETF pricing changes throughout the trading day and there can be no guarantee that an ETF is purchased at the optimal time in terms of market movements. Moreover, due to market fluctuations, ETF brokerage costs, differing demand and characteristics of underlying securities, and other factors, the price of an ETF can be lower that the aggregate market price of its cash and component individual securities (net asset value – NAV) and in each purchased at a premium may be sold as a discount. An ETF is subject to the same market risks as those of its underlying individual securities, and also has internal expenses that can lower investment returns. 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. 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. Annuities are retirement products for those who may have the ability to pay a premium now and want to guarantee they receive certain payments or a return on investment in the future. Annuities are contracts issued by a life insurance company designed to meet requirement or other long-term goals. An annuity is not a life insurance policy. Variable annuities are designed to be long-term investments, to meet retirement and other long- 9  range goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes and insurance company charges may apply if you withdraw your money early. Variable annuities also involve investment risks, just as mutual funds do. 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. Voting Client Securities (Proxy Voting) GCWM 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 7: Client Information Provided to Portfolio Managers All client information material to managing the portfolio (including basic information, risk tolerance, sophistication level, and income level) is provided to the portfolio manager. The portfolio manager will also have access to that information as it changes and is updated. Item 8: Client Contact with Portfolio Managers GCWM does not restrict clients from contacting portfolio managers. GCWM’s representatives can be contacted during regular business hours using the information on the Form ADV Part 2B cover page. 10  Item 9: Additional Information A. Disciplinary Action and Other Financial Industry Activities Criminal or Civil Actions There are no criminal or civil actions to report. Administrative Proceedings There are no administrative proceedings to report. Self-Regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Registration as a Broker/Dealer or Broker/Dealer Representative Neither GCWM nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither GCWM 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. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Neither GCWM nor its representatives have any material relationships to this advisory business that would present a possible conflict of interest. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections GCWM does not select third-party investment advisers. 11  B. Code of Ethics, Client Referrals, and Financial Information Code of Ethics GCWM has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. GCWM’s Code of Ethics is available free upon request to any client or prospective client. Recommendations Involving Material Financial Interests GCWM does not recommend that clients buy or sell any security in which GCWM or a related person has a material financial interest. Investing Personal Money in the Same Securities as Clients From time to time, representatives of GCWM may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of GCWM 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. GCWM will always document any transactions that could be construed as conflicts of interest and will never engage in trading that front runs or operates to the client’s disadvantage when similar securities are being bought or sold. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of GCWM may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of GCWM 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, GCWM will never engage in trading that front runs or operates to the client’s disadvantage if representatives of GCWM buy or sell securities at or around the same time as clients. Frequency and Nature of Periodic Reviews Accounts are reviewed at least annually by Kyle R Louvar, CEO, with regard to clients’ respective investment policies and risk tolerance levels. 12  Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). Content and Frequency of Regular Reports Provided to Clients Each client will receive a quarterly account statement from the custodian. Economic Benefits Provided by Third Parties for Advice Rendered to Clients • Products & Services Available to Us From Schwab Schwab Advisor Services is Schwab’s business serving independent investment advisory firms like ours. They provide us and our clients with access to its institutional brokerage – trading, custody, reporting and related services – many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts while others help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis, at no charge to advisors. • Services that Benefit Client Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit clients or their account(s). • Services that May Not Directly Benefit Clients Schwab also makes available to us other products and services that benefit us but may not directly benefit the client or their account(s). These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or some substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • provides access to client account data (such as duplicate trade confirmations and • account statements); facilitates trade execution and allocate aggregated trade orders for multiple client accounts; • provides pricing and other market data; • facilitates payment of our fees from our clients’ accounts; and 13  • assists with back-office functions, recordkeeping and client reporting. Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: technology, compliance, legal, and business consulting; • educational conferences and events • • publications and conferences on practice management and business succession; and • access to employee benefits providers, human capital consultants and insurance providers. Schwab may provide some of these services itself. In other cases, it will arrange for third- party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Irrespective of direct or indirect benefits to our client through Schwab, we strive to enhance the client’s experience, help reach their goals and put their interests before that of our firm or its associated persons. Compensation to Non – Advisory Personnel for Client Referrals GCWM does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. GCWM may receive client referrals from Zoe Financial, Inc through its participation in Zoe Advisor Network (ZAN). Zoe Financial, Inc is independent of and unaffiliated with GCWM and there is no employee relationship between them. Zoe Financial established the Zoe Advisor Network as a means of referring individuals and other investors seeking fiduciary personal investment management services or financial planning services to independent investment advisors. Zoe Financial does not supervise the Advisor and has no responsibility for GCWM’s management of client portfolios or the Advisor’s other advice or services. GCWM pays Zoe Financial an on-going fee for each successful client referral. This fee is usually a percentage of the advisory fee that the client pays to GCWM (“Solicitation Fee”). GCWM will not charge clients referred through Zoe Advisor Network 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 Zoe Financial Inc, please refer to the Zoe Financial Disclosure and Acknowledgement Form. 14  Balance Sheet GCWM 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. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients GCWM does not have any financial condition that would impair its ability to meet contractual commitments to clients. Bankruptcy Petitions in Previous Ten Years GCWM has not been the subject of a bankruptcy petition. 15