INTEGRITY ROAD WEALTH PARTNERS LLC

Integrity Road Wealth Partners LLC IARD #333154 820 Gessner Road, Suite 300 Houston, TX 77024 832-585-8699 justin.reede@integrityroadwealth.com www.integrityroadwealth.com Form ADV Part 2A Firm Brochure April 8, 2026 This Brochure provides information about the qualifications and business practices of Integrity Road Wealth Partners LLC. If you have any questions about the contents of this Brochure, please contact us at 832-585-8699, or via e-mail at justin.reede@integrityroadwealth. 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. Integrity Road Wealth Partners LLC is a registered investment advisory firm. Registration of an investment advisory firm does not imply a particular level of skill or training. Additional information about Integrity Road Wealth Partners LLC is also available on the SEC’s website at www.adviserinfo.sec.gov.  ITEM 2 Material Changes The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of our Firm Brochure. This Item discusses only specific material changes made to this Brochure and provides our clients with a summary of such changes. Material Changes since the Last Annual Update Since the previous annual filing of this ADV Part 2 (dated January 30, 2026), there have been no material changes made to this version of the Disclosure Brochure. In the future, all material changes will be reported here. Full Brochure and Additional Information Full Brochure and additional information about Integrity Road Wealth Partners LLC are available via the SEC’s website www.adviserinfo.sec.gov. The SEC’s website also provides information about any persons affiliated with us who are registered or are required to be registered as investment adviser representatives (“IAR”). 2  ITEM 3 Table of Contents ITEM 1 Cover Page .................................................................................................................................. 1 ITEM 2 Material Changes ........................................................................................................................ 2 ITEM 3 Table of Contents ....................................................................................................................... 3 ITEM 4 Advisory Business ....................................................................................................................... 4 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, and Risk of Loss ................................................... 8 ITEM 9 Disciplinary Information ...........................................................................................................10 ITEM 10 Other Financial Activities and Affiliations .................................................................................10 ITEM 11 Code of Ethics, Participation in Client Transactions and Personal Trading ..............................10 ITEM 12 Brokerage Practices ..................................................................................................................11 ITEM 13 Review of Accounts ..................................................................................................................14 ITEM 14 Client Referrals and Other Compensation ................................................................................15 ITEM 15 Custody .....................................................................................................................................15 ITEM 16 Investment Discretion ..............................................................................................................16 ITEM 17 Voting Client Securities.............................................................................................................17 ITEM 18 Financial Information................................................................................................................17 3  ITEM 4 Advisory Business FIRM INFORMATION Integrity Road Wealth Partners LLC (“Integrity Road Wealth,” “we,” “us,” “our”), LLC formed in August 2024 is a registered investment advisory firm located in Texas. We have been a registered investment advisory firm since 2024. PRINCIPAL OWNERS Integrity Road Wealth is owned and controlled by Galatians Two Twenty Ventures LLC. Justin Alexander Reede serves as the Managing Member of both entities and is Chief Compliance Officer. INVESTMENT ADVISORY SERVICES Wealth Management Services: We provide wealth management services in which we manage your custodial accounts and provide you with continuous and ongoing supervision of your custodial accounts. We help clients invest in equities, bonds, mutual funds, exchange-traded funds (ETFs), Real Estate Investment Trusts (REITs), options, and additional securities. Financial Planning and Consulting Services: We provide various financial planning and consulting services, finding ways to help you understand your overall financial situation as you set financial objectives. We accomplish this by helping you review your financial goals, tax planning strategies, asset allocation, risk management, retirement planning, and other areas and objectives such as budgeting, education planning, cash flow planning, charitable planning, lines of credit analysis, insurance analysis, business financial planning, mortgage/debt analysis, and real estate analysis. Generally, such financial planning and consulting services will involve preparing a financial plan or rendering a financial consultation based on your financial goals and objectives. We will summarize our recommendations to you in a written plan, which will typically include general recommendations for a course of action or specific actions to be taken by you. Implementation of the recommendations will be at your discretion. Ongoing Financial Planning and Consulting Services Upon completion of the client’s financial plan or consulting engagement, we will periodically revisit all or some of the following areas of analysis: financial goals, tax planning strategies, asset allocation, risk management, retirement planning, and other areas and objectives such as budgeting, education planning, cash flow planning, charitable planning, lines of credit analysis, insurance analysis, business financial planning, mortgage/debt analysis, and estate planning analysis throughout the course of a year via scheduled meetings, calls, or follow-up emails to ensure that the initial recommendations in the financial plan or consulting engagement are implemented or to make adjustments to the financial plan and/or the client objectives. TAILORED INVESTMENT ADVISORY SERVICES AND RESTRICTIONS Integrity Road Wealth offers the same suite of services to clients operating with the same service offering; however, specific recommendations and their implementation are dependent upon the individual client’s current financial situation, such as income, net worth, and risk tolerance levels. 4  On a case-by-case basis, our clients can impose restrictions on investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent us from properly servicing the client’s account, or if the restrictions would require us to deviate from our standard suite of services, we reserve the right to end the relationship. We can request additional information and documentation, such as current investments, tax returns, insurance policies, and estate plans. We will discuss your investment objectives, needs, and goals, but you must inform us of any changes. Unless directed by you, we do not independently verify any information provided to us by you or your attorney, accountant, or other professionals. WRAP FEE PROGRAMS Integrity Road Wealth does not participate in, recommend, or offer wrap fee programs. ASSETS UNDER MANAGEMENT As of January 16, 2026, Integrity Road Wealth manages $123,819,424 on a discretionary basis and $2,143,200 on a non-discretionary basis for combined assets under management of $125,962,624. ITEM 5 Fees and Compensation ANNUAL FEES FOR ADVISORY SERVICES Integrity Road Wealth is compensated for providing wealth management and financial planning services by charging a negotiable fee based on the total assets under management. Note that wealth management clients paying based upon a percentage of assets under management automatically receive financial planning as a part of the offering at no additional cost. The fees and billing will be pre-determined in writing in the Wealth Management Agreement executed by you and Integrity Road Wealth. For clients interested in financial planning only, we may charge negotiable fixed or annual fees, which vary depending on the complexity of the process undertaken, the types of issues addressed, the scope of services provided, the needs of the client, and the frequency with which the services are rendered. All fees are agreed upon before entering the Financial Planning and Consulting Agreement you sign. The below ranges are the standard fee ranges that are typically charged. We will waive the agreed- upon financial planning fees if you engage our wealth management services. Wealth Management Fee Schedule Up to $1,000,000 0.75% Next $1,000,000 0.70% Next $1,000,000 0.60% Next $2,000,000 0.50% Next $5,000,000 0.35% Greater than $10,000,000 0.25% 5  Financial Planning Only Fee Schedule Starting at $5,000 Fixed Fee or Ongoing Annual Planning Fee FEE BILLING & PAYMENT Our wealth management fees are annual fees and are negotiable. Wealth management fees are paid monthly in arrears. Payments are due on the first day of the calendar month and are based on the account’s average daily balance for the prior calendar month multiplied by the applicable annual rate and divided by twelve (12). The fee for the prior month is billed and payable within ten (10) days after the end of the prior month. We will deduct our wealth management fee only when in receipt of your written authorization by executing a Wealth Management Agreement permitting the fees to be paid directly from your account. The qualified custodian will deliver an account statement to you at least quarterly, which will show all disbursements from your account. We urge you to review all statements for accuracy. Your account at the custodian can also be charged for certain additional assets managed for you by us but not held by the custodian (i.e., mutual funds). The Wealth Management Fee will be prorated based on the number of days in the month that the Client was a client of Integrity Road Wealth, or the assets were under Integrity Road Wealth’s management, if: • The Agreement is executed other than the first day of a calendar month; • One of the parties terminates the Agreement; or • The Client prepays advisory fees or withdraws or adds assets to the account. At Integrity Road Wealth’s discretion, the firm may combine the account values of family members or friends to determine the applicable fee. Combining account values may increase the asset total, ultimately resulting in the Client(s) paying a reduced Wealth Management Fee based on the available breakpoints in the fee schedule laid out above. Financial planning fees are assessed as a one-time project fee, or as an annual fee payable either monthly or quarterly. For one-time projects, the Client agrees to pay one-half of the total fee upon signing the Financial Planning and Consulting Agreement and the remaining fee upon delivery of the plan. For ongoing financial planning services, the Client agrees to pay a one-time initial planning fee in addition to an annual fee paid out either monthly or quarterly, arrears. Ongoing financial planning will automatically renew annually unless terminated by either the client or Integrity Road Wealth. We will not require a fee of $1,200 or more to be paid six months or more in advance. Financial planning and consulting fees are paid via check or by direct invoicing via an electronic payment processor. You are responsible for all third-party fees (i.e., custodian fees, mutual fund fees, transaction fees, etc.). These fees are separate and distinct from the fees and expenses charged by Integrity Road Wealth. Although Integrity Road Wealth has established the above fee schedule(s), we retain the discretion to negotiate alternative fees and billing frequency on a client-by-client basis. Client facts, circumstances and needs are considered in determining the fee schedule. These include the complexity of the client, assets to be placed under management, anticipated future additional assets; related accounts; portfolio style, account composition, reports, among other factors. The specific annual fee schedule and frequency is identified in the contract between the Advisor and each client. 6  TERMINATION OF AGREEMENT Either party can terminate the agreement by providing 30-day advance written notice. Upon termination of any account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable up to and including the effective date of termination. Notwithstanding the above, if we do not deliver the appropriate disclosure statement to you at least 48 hours prior to you entering into any written or oral advisory contract with us, then you have the right to terminate the contract without penalty within five (5) business days after entering into the contract. OTHER EXPENSES AND FEES The fees discussed above include payment solely for the investment advisory services provided by us and are separate from certain fees or charges that are imposed by third parties in connection with investments made on your behalf for your account. Third-party fees can include markdowns, markups, brokerage commissions, other transaction costs, and/or custodial fees. The advisory fee is exclusive of direct out-of- pocket costs incurred by Integrity Road Wealth. Integrity Road Wealth is entitled to reimbursement from clients for any and all costs and expenses (including taxes, producing and delivery of physical copies of documents and reports etc.) incurred by Integrity Road Wealth as a result of providing its advisory services to the Client. All fees paid to us for wealth management services are separate from the expenses charged by exchange- traded funds and mutual funds to their shareholders. These fees and expenses will be used to pay management fees for the funds, other fund expenses, account administration, and a possible distribution fee. Exchanged traded funds and mutual funds can be invested in directly by you without our services. However, you would not receive our services to assist you in determining which products or services are most suitable for your financial situation and objectives. You should review both the fees we charge, and the fees charged by the fund(s) to understand the total fees to be paid fully. Please refer to Item 12 of this brochure for a more detailed explanation of brokerage practices. OTHER COMPENSATION No other compensation is earned by the firm or its principals. ITEM 6 Performance-Based Fees and Side-By-Side Management We do not charge any performance-based fees, which are fees based on a share of capital gains on or capital appreciation of your assets. ITEM 7 Types of Clients We provide our investment advisory services to: -Individuals -High Net Worth Individuals Our minimum account size requirements for opening or maintaining an account with us are as follows: -$1,000,000 in AUM or $7,500 in fees (subject to firm discretion); maximum threshold subject to 3% of assets under management 7  -There is no minimum amount of assets required to receive stand-alone financial planning services. ITEM 8 Methods of Analysis, Investment Strategies, and Risk of Loss METHODS OF ANALYSIS We use various methods of analysis and investment strategies, including the following: Fundamental Analysis – We evaluate economic and financial factors to determine if a security can be underpriced, overpriced, or fairly priced. This method entails assessing a security by attempting to determine its intrinsic value by examining related financial, economic, and other qualitative and quantitative factors. Fundamental analysis requires an in-depth look at all factors that can affect the security's value, from macroeconomic factors (like the overall economy and industry conditions) to individually specific factors (like the financial situation and management of companies). The overall objective of performing the fundamental analysis is to determine a value that an investor can use to determine what sort of position to take with that security. This method of security analysis is contrary to technical analysis. Fundamental analysis involves using real data to evaluate a security's value. Although most analysts use fundamental analysis to value stocks, this method of valuation can be used for just about any type of security. Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Therefore, unforeseen market conditions and/or company developments can result in significant price fluctuations that can lead to investor losses. Technical Analysis – This method involves the evaluation of securities by performing an analysis of statistical information that is generated by market activity, such as past prices and volume. Technical analysis does not attempt to measure a security's intrinsic value but instead use charts and other tools to determine the patterns that can suggest future activity. Technical analysts believe that the historical performance of stocks and markets are indications of future performance. A substantial risk in relying upon technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that we will be able to accurately predict such a reoccurrence. Modern Portfolio Theory - Modern portfolio theory (MPT) is a risk-averse theory that involves the construction of portfolios to maximize and optimize expected return based on a given level of market risk, emphasizing that risk is an inherent part of higher reward. According to the theory, it's possible to construct an "efficient frontier" of optimal portfolios offering the maximum possible expected return for a given level of risk. MPT tries to understand the market as a whole and measure market risk in an attempt to reduce the inherent risks of investing in the market. However, with every financial investment strategy, there is a risk of a loss of principal. Not every investment decision will be profitable, and there can be no guarantee of any level of performance. 8  INVESTMENT STRATEGIES When formulating investment advice or managing client assets, we will use the following investment strategies. There are inherent risks associated with each of these strategies. Long-Term Strategy - A long-term strategy cannot take advantage of short-term gains or can experience more volatility over the life of the portfolio. Your accounts are managed separately with your underlying investment strategies, restrictions, or investment limitations defined within the investment management agreement. Custom Indexing – We can buy securities underlying a mutual fund or exchange-traded-fund (ETF) in order to track such a fund without the underlying costs. POTENTIAL RISKS Investing involves different levels of risk that can result in loss of any profits and/or principal you have not realized. We manage your account in a manner consistent with your pre-determined risk tolerance and suitability profile. However, we cannot guarantee that our efforts will be successful. Investing in securities involves the risk of loss that clients should be prepared to bear. Investing involves the assumption of risk, including: Financial Risk: which is the risk that the companies we recommend to you perform poorly, which affects the price of your investment. Market Risk: which is the risk that the stock market will decline, decreasing the value of the securities we recommend to you. Inflation Risk: which is the risk that the rate of price increases in the economy deteriorates the returns associated with the stock or bond. Political and Governmental Risk: which is the risk that the value of your investment will is affected by the introduction of new laws or regulations. Interest Rate Risk: which is the risk that the value of the investments we recommend to you will fall if interest rates rise. Call Risk: which is the risk that your investment will be called or purchased back from you when conditions are favorable to the bond issuer and unfavorable to you. Default Risk: which is the risk that issuer is unable to pay the contractual interest or principal on the investment promptly or at all. Manager Risk: which is the risk that an actively managed mutual fund’s investment adviser will fail to execute the fund’s stated investment strategy. Industry Risk: which is the risk that a group of stocks in a single industry will decline in price due to adverse developments in that industry, decreasing the value of mutual funds that are significantly invested in that industry. Index or Fund Tracking Error – with custom indexing, there is a possibility that you will experience some tracking error. Tracking error is a measure of how your performance may differ from that of the tracked 9  fund. Tracking error, positive or negative, may be due to lack of adequate holdings updating from the fund provider with quarterly or monthly security reports, inability to trade at the same time as trades occur in the underlying fund, and differences in fees or underlying securities. ITEM 9 Disciplinary Information As of the date of this brochure, we have not been subject to any disciplinary, legal, or regulatory events related to past or present investment clients. There has been no disciplinary, legal, or regulatory events related to us or any of our management persons. ITEM 10 Other Financial Activities and Affiliations FINANCIAL INDUSTRY ACTIVITIES Neither Integrity Road Wealth nor its management persons are registered or has an application pending to register as a broker-dealer or a registered representative of a broker-dealer. Neither Integrity Road Wealth nor its management persons are registered or has an application pending to register as a futures commission merchant, commodity pool operator, or commodity trading advisor. SELECTION OF OTHER INVESTMENT ADVISERS We do not recommend or select third party investment advisers. ITEM 11 Code of Ethics, Participation in Client Transactions and Personal Trading CODE OF ETHICS Integrity Road Wealth has developed a code of ethics that will apply to all of our supervised persons. We and our IARs must act in a fiduciary capacity when providing investment advisory services to you. As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our clients at all times. Integrity Road Wealth has a fiduciary duty to all clients. This fiduciary duty is considered the core underlying principle of our code of ethics, which also covers our insider trading and personal securities transactions policies and procedures. We require all of our supervised persons to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws at all times. Upon employment or affiliation and at least annually thereafter, all supervised persons will acknowledge that they have read, understand, and agree to comply with our Code of Ethics. Our Code of Ethics is available to clients and prospective clients upon request. RECOMMENDATIONS INVOLVING A MATERIAL FINANCIAL INTEREST Neither we nor any related person recommend to clients or buys or sells for clients’ accounts securities in which we or a related person has a material financial interest. 10  PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS There are instances where an IAR will recommend to investment advisory clients or prospective clients the purchase or sale of securities in which an IAR, its affiliates, or other clients can also have a position or interest. Certain affiliated accounts can trade in the same securities with client accounts on an aggregated basis. Generally, in such circumstances, the affiliated and client accounts will share execution costs equally. Completed trade orders will be allocated according to the instructions from the initial trade order. Partially filled trade orders will be allocated on a pro-rata basis. Any exceptions will be explained in the trade order. PERSONAL TRADING Employees are permitted to have personal securities accounts as long as personal investing practices are in line with fiduciary standards and regulatory requirements and do not conflict with their duty to Integrity Road Wealth and our clients. Integrity Road Wealth monitors and controls personal trading through pre- approval of all personal securities transactions or blackout periods imposed upon employees trading in the same securities as Integrity Road Wealth. We forbid any officer or employee, either personally or on behalf of others, to trade on material, nonpublic information or to communicate such information to others in violation of the law. ITEM 12 Brokerage Practices Integrity Road Wealth does not maintain custody of your assets that we manage, although we are deemed to have custody of your assets if you give us authority to withdraw assets from your account (see Item 15—Custody, below). Your assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. We recommend that our clients use Charles Schwab & Co., Inc. (“Schwab”), a registered broker-dealer and member of SIPC, as the qualified custodian. We are independently owned and operated and are not affiliated with Schwab. Schwab will hold your assets in a brokerage account and buy and sell securities when we instruct them. While we recommend that you use Schwab as a custodian/ broker, you will decide whether to do so and will open your account with Schwab by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. We do not open the account for you, although we can assist you in doing so. Not all advisors require their clients to use a particular broker-dealer or other custodian selected by the advisor. Even though your account is maintained at Schwab, and we anticipate that most trades will be executed through Schwab, we can still use other brokers to execute trades for your account as described below (see “Your brokerage and custody costs”). We recommend Schwab, a custodian/ broker, to hold your assets and execute transactions. When considering whether the terms that Schwab provides are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: • Combination of transaction execution services and asset custody services (generally without a separate fee for custody • Capability to execute, clear, and settle trades (buy and sell securities for your account) 11  • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payments, etc. • Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds (ETFs), etc.) • Availability of investment research and tools that assist us in making investment decisions • Quality of services • Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices • Reputation, financial strength, security, and stability • Prior service to us and our clients • Services delivered or paid for by Schwab • Availability of other products and services that benefit us, as discussed below (see “Products and services available to us from Schwab”) Your brokerage and custody costs For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. Certain trades (for example, equities and ETFs) do not incur Schwab commissions or transaction fees. Schwab is also compensated by earning interest on the uninvested cash in your account in Schwab’s Cash Features Program. For some accounts, Schwab could charge you a percentage of the dollar amount of assets in the account in lieu of commissions. In addition to asset-based fees, Schwab could charge you a flat dollar amount as a “prime broker” or “trade away” fee for each trade that we have executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into your Schwab account. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. Because of this, in order to minimize your trading costs, we have Schwab execute most trades for your account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through Schwab, we have determined that having Schwab execute most trades is consistent with our duty to seek the “best execution” of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see “How we select brokers/custodians”). By using another broker or dealer, you can pay lower transaction costs. RESEARCH AND OTHER BENEFITS We receive soft dollar benefits in that certain custodians can make other products and services available to us, such as trade execution software, investment research, pricing information, market data, recordkeeping, publications, and conferences in return for effecting transactions through them. Such arrangements will be pursuant to Section 28(e) of the Securities and Exchange Act of 1934 and are available to all of the retail and professional clients of the custodians on an unsolicited basis. Products & Services Available to Us from Schwab Schwab Advisor Services (formerly called Schwab Institutional) 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 12  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 and at no charge to us as long as we maintain a total of at least $10 million of our clients’ assets in accounts at Schwab. 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 cannot 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 can 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 allocates aggregated trade orders for multiple client accounts; • provides pricing and other market data; • facilitates payment of our fees from our clients’ accounts; and • 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: • educational conferences and events • technology, compliance, legal, and business consulting; • publications and conferences on practice management and business succession; and • access to employee benefits providers, human capital consultants, and insurance providers. Schwab can provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab can 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. BROKERAGE FOR CLIENT REFERRALS We do not receive client referrals from broker-dealers. 13  DIRECTED BROKERAGE Clients will be permitted to select any broker-dealer of their choosing. In these situations, we are unable to achieve the most favorable execution for client transactions. Directing brokerage can cost clients more money in that the client can pay higher brokerage commissions because we are not able to aggregate orders to reduce transaction costs, or the client can receive less favorable prices. TRADE AGGREGATION Transactions for the Account will generally be made independently of transactions in other client accounts unless Integrity Road Wealth decides to purchase or sell the same securities for several clients at approximately the same time. Integrity Road Wealth may, in its discretion, combine transactions in the same securities for multiple clients at approximately the same time to obtain the best execution, negotiate more favorable commission rates or fairly allocate differences in prices, commissions, and other transaction costs among clients. When Integrity Road Wealth aggregates transactions, it will, or have the Custodian, average the executed prices of the aggregated transactions and allocate the transactions in proportion to the orders placed for each client on any given day. The Account will be deemed to have purchased or sold its proportionate share of the instruments involved at the average price obtained. Integrity Road Wealth will not receive any additional compensation or remuneration from aggregating multiple client orders. If the Client directs Integrity Road Wealth to use a specific broker-dealer to execute some or all transactions for the Client’s account, Integrity Road Wealth is not obligated to seek better execution services or prices from other broker-dealers or aggregate the Client’s transactions for execution through other broker- dealers with orders for other client accounts managed by Integrity Road Wealth, particularly since they may not be using the same broker-dealer). As a result, the Client may pay higher commissions or other transaction costs or greater spreads or receive less favorable net prices on transactions for the account that would otherwise be the case. The Client understands that Integrity Road Wealth would be in a better position to negotiate brokerage commissions by aggregating the Client’s transactions with those of other clients if the Client had not directed Integrity Road Wealth to use a specific broker. ITEM 13 Review of Accounts PERIODIC REVIEWS We review asset management accounts no less than semi-annually. These accounts will be reviewed by the CCO or his designee. Accounts are reviewed to evaluate asset allocation, investment strategy and objectives, cash balance, and performance, as well as the general economic outlook and current investment trends. Financial plans created utilizing our ongoing financial planning services will be reviewed semi-annually. Project-based financial planning clients are provided a one-time plan or consulting session and receive no additional reviews unless a new financial planning and consulting agreement is executed. 14   REVIEW TRIGGERS We conduct periodic reviews to evaluate the current market, economic and political events and how these can affect client accounts. Additional reviews can be triggered by these events or by events in the client’s financial or personal status. REGULAR REPORTS Wealth management clients will receive advisory account reports no less than quarterly. These reports show asset value by cash balances, security, unit cost, total cost, current per share values, etc. Clients are urged to review the quarterly reports provided by us with those provided by their custodians and notify us of any differences. Clients are encouraged to phone or e-mail us as often as they deem necessary to receive information regarding the investment tactics and strategies being followed. Financial plans created utilizing our ongoing financial planning services will receive status updates and/or reports during plan reviews. We can make adjustments to the Client’s financial plan and/or the Client’s objectives. Project-based financial planning and consulting clients are provided a one-time written financial plan concerning their financial situation. After the presentation of the plan, there are no further reports unless the relationship is an ongoing consulting arrangement for financial planning-only. Wealth management clients may also receive quarterly written reports evaluating the performance of the plan’s investments as well as comparing the performance thereof to benchmarks or as otherwise determined in our judgment. The information used to generate the reports will be derived from a third party. ITEM 14 Client Referrals and Other Compensation We receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab. In addition, Schwab has also agreed to pay for certain products and services for which we would otherwise have to pay once the value of our clients’ assets in accounts at Schwab reaches a certain size. [In some cases, a recipient of such payments is an affiliate of ours or another party which has some pecuniary, financial, or other interests in us (or in which we have such an interest)]. You do not pay more for assets maintained at Schwab as a result of these arrangements. However, we benefit from the arrangement because the cost of these services would otherwise be borne directly by us. You should consider these conflicts of interest when selecting a custodian. The products and services provided by Schwab, how they benefit us, and the related conflicts of interest are described above (see Item 12 – Brokerage Practices). IRWP maintains a paid listing on a third-party website. The listing primarily functions as a directory-style resource that allows prospective clients to identify advisers whose business model aligns with their preferences. ITEM 15 Custody Under government regulations, we are deemed to have custody of your assets if, for example, you authorize us to instruct Schwab to deduct our advisory fees directly from your account or if you grant us authority to move your money to another person’s account. Schwab maintains actual custody of your assets. You will receive account statements directly from Schwab at least quarterly. They will be sent to 22  the email or postal mailing address you provided to Schwab. You should carefully review those statements promptly when you receive them. We also urge you to compare Schwab’s account statements with the periodic account statements and/or portfolio reports you will receive from us. We are deemed to have custody as a result of our Standing Letters of Authorization (“SLOA(s)”) to transfer funds from their account to third parties. In such instances where we act under such a SLOA, it is our policy to only initiate these transactions when directed by the client to transfer funds to a third party the client designates for a designated amount and at a designated time, all of their choosing. A surprise examination is not required in this circumstance in which we are deemed to have custody due to SLOAs, as we are relying on the conditions set forth in the No-Action letter issued by the Securities and Exchange Commission on February 21, 2017. Pursuant to the conditions set forth in the No-Action Letter, we confirm that in those situations • you provide an instruction to the qualified custodian, in writing, that includes your signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed; • you authorize us, in writing, either on the qualified custodian’s form or separately, to direct • transfers to the third party either on a specified schedule or from time to time; the qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify your authorization, and the qualified custodian provides a transfer of funds notice to you promptly after each transfer; • you have the ability to terminate or change the instruction to the qualified custodian; • we have no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in your instruction; • we maintain records showing that the third party is not a related party of Integrity Road Wealth • or located at the same address as Integrity Road Wealth; and the qualified custodian sends you, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. ITEM 16 Investment Discretion DISCRETIONARY AUTHORITY FOR TRADING If you are participating in our wealth management services, upon receiving your written authorization via our executed investment advisory agreement, we will maintain trading authorization over your designated accounts and can also implement trades on a discretionary basis. When discretionary authority is granted, we will have the limited authority to determine the type of securities to be purchased, sold, or exchanged and a number of securities that can be bought, sold, or exchanged for your portfolio without obtaining your consent for each transaction. If you do not grant this limited investment discretion, your IAR will be required to contact you and get affirmation regarding our investment recommendations, such as the security being recommended, the number of shares, and whether the security should be bought or sold before implementing changes in your account. Once the above factors are agreed upon, we will be responsible for making decisions regarding the timing of buying or selling an investment and the price at which the investment is bought or sold. If your accounts 23  are managed on a non-discretionary basis, it is critical that you respond promptly. If we do not receive a response to our request immediately, the timing of trade implementation can lead to an adverse impact where we cannot achieve the optimal trading price. On a case-by-case basis, you can place reasonable restrictions on the types of investments that can be purchased or sold in your account so long as the restrictions are explicitly set forth or included as an attachment to the investment advisory agreement. ITEM 17 Voting Client Securities We do not have the authority to vote proxies as it pertains to the issuers of securities held in your account. The responsibility for voting your securities places increased liability to us and does not add enough value to the services provided to you to justify the additional compliance and regulatory costs associated with voting your securities. Therefore, you are responsible for voting all proxies for securities held in accounts managed by us. Typically, our qualified custodian will forward you your proxy information. Although we do not vote your proxies, you can contact us if you have a question about a particular proxy. ITEM 18 Financial Information We will not require a fee of $1,200 or more to be paid six months or more in advance. We are not required to include a balance sheet for our most recent fiscal year. We are not subject to a financial condition that is reasonably likely to impair our ability to meet contractual commitments to our clients. We are currently not in, nor have we been historically, in a financially precarious situation or the subject of a bankruptcy petition. 24