IVC WEALTH ADVISORS LLC

IVC Wealth Advisors LLC Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of IVC Wealth Advisors LLC. If you have any questions about the contents of this brochure, please contact us at (215) 392-6631 or by email at: info@ivcwealth.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 IVC Wealth Advisors LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. IVC Wealth Advisors LLC’s CRD number is: 301127. 163 E. Main Street P.O. Box 539 Silverdale, PA 18962 (215) 392-6631 info@ivcwealth.com https://ivcwealth.com Registration as an investment adviser does not imply a certain level of skill or training. Version Date: 08/28/2025 i  Item 2: Material Changes The material changes in this brochure from the last annual updating amendment of IVC Wealth Advisors LLC on 03/08/2025, are described below. Material changes relate to IVC Wealth Advisors LLC’s policies, practices or conflicts of interest. • IVC Wealth Advisors LLC has updated Other Business Activity. (Item 10.C) ii  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ....................................................................................................................................... ii Item 3: Table of Contents ...................................................................................................................................... iii Item 4: Advisory Business ......................................................................................................................................2 Item 5: Fees and Compensation .............................................................................................................................5 Item 6: Performance-Based Fees and Side-By-Side Management ....................................................................8 Item 7: Types of Clients ..........................................................................................................................................8 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ...............................................................9 Item 9: Disciplinary Information .........................................................................................................................12 Item 10: Other Financial Industry Activities and Affiliations .........................................................................13 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 ....................................................................................................................................................20 Item 16: Investment Discretion ............................................................................................................................20 Item 17: Voting Client Securities (Proxy Voting) ..............................................................................................21 Item 18: Financial Information .............................................................................................................................21 iii  Item 4: Advisory Business A. Description of the Advisory Firm IVC Wealth Advisors LLC (hereinafter “IVCWA”) is a Limited Liability Partnership organized in the State of Pennsylvania. The firm was formed in November 2014, and the principal owner is Eric Vaughn Landes. B. Types of Advisory Services Portfolio Management Services IVCWA offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. IVCWA creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: • • • Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring IVCWA evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. IVCWA 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. IVCWA seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of IVCWA’s economic, investment or other financial interests. To meet its fiduciary obligations, IVCWA attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, IVCWA’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 IVCWA’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. 2  Pension Consulting Services IVCWA 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. Selection of Other Advisors From time to time, IVC Wealth Advisors, LLC may recommend that our clients use the services of a third-party money manager ("TPMM") to manage all, or a portion of, their investment portfolio. After gathering information about our clients’ financial situation and objectives, we may recommend that our clients engage a specific TPMM or investment program. Factors that we take into consideration when making our recommendation(s) include, but are not limited to, the following: the TPMM's performance, methods of analysis, fees, our clients’ financial needs, investment goals, risk tolerance, and investment objectives. We will monitor the TPMM's performance to ensure its management and investment style are consistent with our clients’ investment goals and objectives. We will assume discretionary authority to hire and fire TPMM(s) and/or reallocate our clients’ assets to other TPMM(s) where we deem such action appropriate. Platform Provider and Subadvisory Arrangement with Vise We have engaged Vise as a platform provider and subadvisor to assist with managing certain clients’ investment portfolios. We maintain discretionary authority to hire and fire Vise. Vise employs automated asset allocation, portfolio analysis, tax management, portfolio rebalancing, and portfolio selection strategies for intermediaries, including us. As part of the service, we are granted access to Vise’s secure website as a tool to monitor and manage client assets. We use Vise’s interactive online platform to create and manage a desired investment strategy for clients. Among other features, Vise’s platform allows us to customize how much exposure to take with respect to specific factors (known as an “active tilt”) such as value, dividend, and size. Vise bases its advice on client investment objectives, restrictions, and preferences, as provided by us and in accordance with the agreements we have entered with Vise. 3  Clients do not have direct access to the Vise platform, and we are responsible for the management of the client’s assets on the Vise platform. Clients must notify us of any specific stocks or securities in which the client is prohibited from investing, and we, in turn, are responsible for notifying Vise. Vise does not verify any information they receive from us or our agent(s) for accuracy. It is our responsibility to promptly notify Vise if there are ever any changes in our client's financial situation or investment objectives. For more information concerning Vise’s investment methods, fees, and risks, please see the Vise Form ADV Brochure. Services Limited to Specific Types of Investments in the gold and precious metal sectors), treasury IVCWA generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, ETFs (including ETFs inflation protected/inflation linked bonds, commodities and non-U.S. securities. IVCWA may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions IVCWA will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by IVCWA on behalf of the client. IVCWA may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. We factor in tax consequences as it relates to asset management. We can customize, at the account level, "do not sell" restrictions on specific holdings. We will also accommodate those clients who wish to be socially conscience investors. These special considerations are identified in the client's investment policy statement. 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 IVCWA from properly servicing the client account, or if the restrictions would require IVCWA to deviate from its standard suite of services, IVCWA reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. IVCWA does not participate in wrap fee programs. E. Assets Under Management IVCWA has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 400,087,780.00 $ 5,132,398.00 December 2024 4  Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees Total Assets Under Management Annual Fees All Assets Up to 1.50% The advisory fee is calculated using the value of the assets in the Account on the last business day of the prior billing period. 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 IVCWA's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract immediately upon written notice. Pension Consulting Services Fees Asset-Based Fees for Pension Consulting Total Assets Under Management Annual Fee All Assets Up to 1.00% IVCWA 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. 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 IVCWA's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the pension consulting agreement immediately upon written notice. IVCWA 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. Fixed Fees 5  The rate for creating client pension consulting plans is between $500 and $50,000. The final fee schedule will be memorialized in the client’s advisory agreement. This service may be canceled immediately upon written notice. Selection of Other Advisors Fees Total Assets Under Management Vise’s Fee Annual Fee 0.35% All Assets 0.35% For existing IVC Wealth Advisors, LLC client accounts as of October 15, 2020, Advisory fees charged by Vise are separate and apart from our advisory fees. Assets managed by Vise will be included in calculating our advisory fee, which is based on the fee schedule set forth in the Fees and Compensation section in this brochure. Advisory fees that you pay to Vise are negotiated between us and Vise. For new clients after October 15th, 2020, we have negotiated an arrangement with Vise where you are not responsible for paying Vise directly, and we will pay Vise from our portfolio management fee. You should review Vise’s brochure for information on its fees and services. 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 quarterly basis. Fees are paid in advance. For new clients with limited assets, an option to pay an annual fixed fee for IVC’s advisory services, payable in four equal quarterly advance installments, is available via ACH and check. The fee (amount and/or type) is subject to future written modification presented by IVC to the client for execution. Payment of Administrative Fees IVC Wealth Advisors, LLC may be requested by clients to provide administrative assistance to establish retail donor accounts maintained at Charles Schwab & Co., Inc. The account is a retail investment account into which donations of marketable securities are made for the benefit of the client’s designated charity. The client shall pay IVC an annual administrative fee for the assistance, payable quarterly, in advance. Unlike services provided by IVC for other accounts maintained by the client, the assistance shall not include any investment advice or recommendations, nor any initial or ongoing account investment supervisory, monitoring, or reporting services. Payment of Pension Consulting Fees 6  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. Fixed pension consulting fees are paid via ACH and check. These fees are paid in arrears upon completion. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by IVCWA. Please see Item 12 of this brochure regarding broker-dealer/custodian. D. Prepayment of Fees IVCWA collects certain fees in advance and certain fees in arrears, as indicated above. Refunds for fees paid in advance but not yet earned will be refunded on a prorated basis and returned within thirty days to the client via check, or return deposit back into the client’s account. For all asset-based fees paid in advance, the fee refunded will be equal to the balance of the fees collected in advance minus the daily rate* times the number of days elapsed in the billing period up to and including the day of termination. (*The daily rate is calculated by dividing the annual asset-based fee rate by 365.) E. Outside Compensation For the Sale of Securities to Clients David William Gotwals, Ronald Jack Joyce, Jr., Eric Vaughn Landes, Scott Cendali and Paul Joseph McColgan are registered representatives of a broker-dealer. David William Gotwals, Ronald Jack Joyce, Jr., Eric Vaughn Landes, Scott Cendali and Paul Joseph McColgan are also insurance agents. In these roles, they accept compensation for the sale of investment products to IVCWA clients. 1. This is a Conflict of Interest Supervised persons may accept compensation for the sale of investment products, including asset based sales charges or service fees from the sale of mutual funds to IVCWA's clients. This presents a conflict of interest and gives the supervised person an incentive to recommend products based on the compensation received rather than on the client’s needs. When recommending the sale of investment products for which the supervised persons receives compensation, IVCWA will document the conflict of interest in the client file and inform the client of the conflict of interest. 7  2. Clients Have the Option to Purchase Recommended Products From Other Brokers Clients always have the option to purchase IVCWA recommended products through other brokers or agents that are not affiliated with IVCWA. 3. Commissions are not IVCWA's primary source of compensation for advisory services Commissions are not IVCWA’s primary source of compensation for advisory services. 4. Advisory Fees in Addition to Commissions or Markups Advisory fees that are charged to clients are not reduced to offset the commissions or markups on investment products recommended to clients. Item 6: Performance-Based Fees and Side-By-Side Management IVCWA 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. Item 7: Types of Clients IVCWA generally provides advisory services to the following types of clients: ❖ ❖ ❖ ❖ ❖ Individuals High-Net-Worth Individuals Pension and Profit Sharing Plans Charitable Organizations Corporations or Business Entities There is no account minimum for any of IVCWA’s services. Clients eligible to enroll in the Program include individuals, IRA’s and revocable living trusts. Clients that are organizations (such as corporations and partnerships) or government entities, and clients that are subject to the Employee Retirement Income Security act of 1974, are not eligible for the Program. The minimum investment required to open or convert an account in the Program is $2,500. The minimum account balance to enroll in the tax-loss harvesting feature is $50,000. 8  Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis IVCWA’s methods of analysis include Fundamental analysis, Modern portfolio theory and Quantitative analysis. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset. Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such as the character of management or the state of employee morale, such as the value of assets, the cost of capital, historical projections of sales, and so on. Investment Strategies IVCWA uses long term trading, short term trading, margin transactions and options trading (including covered options, uncovered options, or spreading strategies). Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The 9  implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Quantitative analysis Investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. Investment Strategies IVCWA's use of margin transactions and options trading generally holds greater risk, and clients should be aware that there is a material risk of loss using any of those strategies. Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Margin transactions use leverage that is borrowed from a brokerage firm as collateral. When losses occur, the value of the margin account may fall below the brokerage firm’s threshold thereby triggering a margin call. This may force the account holder to either allocate more funds to the account or sell assets on a shorter time frame than desired. Options transactions involve a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value, as well as the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Short term trading risks include liquidity, economic stability, and inflation, in addition to the long term trading risks listed above. Frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized IVCWA's use of margin transactions and options trading generally holds greater risk of capital loss. Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. 10  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. 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. Real estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. 11  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. Commodities are tangible assets used to manufacture and produce goods or services. Commodity prices are affected by different risk factors, such as disease, storage capacity, supply, demand, delivery constraints and weather. Because of those risk factors, even a well-diversified investment in commodities can be uncertain. Options are contracts to purchase a security at a given price, risking that an option may expire out of the money resulting in minimal or no value. An uncovered option is a type of options contract that is not backed by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option positions entail buying and selling multiple options on the same underlying security, but with different strike prices or expiration dates, which helps limit the risk of other option trading strategies. Option transactions also involve risks including but not limited to economic risk, market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate risk. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. 12  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 IVCWA 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 IVCWA 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 David William Gotwals is a licensed insurance agent with IVC Wealth Advisors LLC, and from time to time, will offer clients advice or products from those activities. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. IVCWA always acts in the best interest of the client; including the sale of commissionable products to advisory clients. Clients are in no way required to utilize the services of any representative of IVCWA in connection with such individual's activities outside of IVCWA. David Gotwals is a Partner at IVC III LLC. David does not devote any hours to the business or receive compensation from it. David Gotwals is a Partner at IVC Properties LLC, a real estate investment firm. He dedicates 1 hour per month outside of trading hours to the business. He expects to derive 1% of his total yearly compensation from this business. David Gotwals works as an Employee at Clear Employer Services, a Professional Employer Organization. He devotes 134 hours per month during trading hours and 160 hours outside trading hours, with no expected compensation derived from the business. Ronald Jack Joyce, Jr. is a licensed insurance agent with IVC Wealth Advisors LLC, and from time to time, will offer clients advice or products from those activities. Clients should 13  be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. IVCWA always acts in the best interest of the client; including the sale of commissionable products to advisory clients. Clients are in no way required to utilize the services of any representative of IVCWA in connection with such individual's activities outside of IVCWA. Ronald Jack Joyce is a Partner at IVC III LLC, dedicating 1 hour per month outside trading hours to the business. He does not expect any portion of his total yearly compensation to be derived from this role. total yearly compensation from this Ronald Jack Joyce is a Partner at IVC Properties LLC, a real estate investment firm. He dedicates 1 hour per month outside of trading hours to the business. He expects to derive 1% of his investment-related business. Ronald Joyce is the Commander and Board member at Telford VFW, serving as a tie- breaker on business matters when necessary. He devotes 10 hours per month outside trading hours to the organization and does not expect any compensation from it. Ronald Jack Joyce, Jr. works as an Employee at Clear Employer Services, a Professional Employer Organization. He devotes 134 hours per month during trading hours and 160 hours outside trading hours, with no expected compensation derived from the business. Eric Vaughn Landes is a licensed insurance agent with IVC Wealth Advisors LLC, and from time to time, will offer clients advice or products from those activities. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. IVCWA always acts in the best interest of the client; including the sale of commissionable products to advisory clients. Clients are in no way required to utilize the services of any representative of IVCWA in connection with such individual's activities outside of IVCWA. Eric Vaughn Landes is Partner at IVC III LLC. He does not allocate any hours during or outside trading hours to the business, nor does he expect any compensation from it. Eric Vaughn Landes is a Partner at IVC Properties LLC, dedicating 1 hour per month outside trading hours to the business. He expects 1% of his total yearly compensation to come from this role. Eric Vaughn Landes works as an Employee at Clear Employer Services, a Professional Employer Organization. He devotes 134 hours per month during trading hours and 160 hours outside trading hours, with no expected compensation derived from the business. Eric Vaughn Landes is a Partner at Adele Properties, a real estate ownership and management business. He devotes 1 hour per month outside trading hours to the business, with no expected compensation derived from it. 14  Paul Joseph McColgan is a licensed insurance agent with IVC Wealth Advisors, and from time to time, will offer clients advice or products from those activities. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. IVCWA always acts in the best interest of the client; including the sale of commissionable products to advisory clients. Clients are in no way required to utilize the services of any representative of IVCWA in connection with such individual's activities outside of IVCWA. Paul McColgan works as an Employee CCO at Clear Employer Services, a Professional Employer Organization. He devotes 134 hours per month during trading hours and 160 hours outside trading hours, with no expected compensation derived from the business. Scott Cendali is a licensed insurance agent with IVC Wealth Advisors LLC, and from time to time, will offer clients advice or products from those activities. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. IVCWA always acts in the best interest of the client; including the sale of commissionable products to advisory clients. Clients are in no way required to utilize the services of any representative of IVCWA in connection with such individual's activities outside of IVCWA Scott Cendali works as an Employee at Clear Employer Services, a Professional Employer Organization. He devotes 134 hours per month during trading hours and 160 hours outside trading hours, with no expected compensation derived from the business. Julie Ann MacDade works as an Employee at Clear Employer Services, a Professional Employer Organization. She devotes 134 hours per month during trading hours and 160 hours outside trading hours, with no expected compensation derived from the business. IVCWA presents several client events over the course of a year. For some events, IVCWA vendors (mutual fund companies, insurance companies, or record keepers) help with client event sponsorship and may mitigate IVCWA’s costs by providing partial payments to event providers directly. This causes a conflict in that the firm has an incentive to direct business to the vendors/fund companies who provide event sponsorship assistance. The firm mitigates this by permitting multiple vendors/fund companies to co-sponsor events with the firm. The firm will always act in the client's best interest without regard to event sponsorship. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections IVCWA may direct clients to third-party investment advisers. Clients will pay IVCWA its standard fee in addition to the standard fee for the advisers to which it directs those clients. The fees will not exceed any limit imposed by any regulatory agency. IVCWA will always act in the best interests of the client, including when determining which third party 15  investment adviser to recommend to clients. IVCWA will ensure that all recommended advisers are exempt, licensed or notice filed in the states in which IVCWA is recommending them to clients. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics IVCWA 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. IVCWA's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests IVCWA does not recommend that clients buy or sell any security in which a related person to IVCWA or IVCWA has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of IVCWA may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of IVCWA 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. IVCWA will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of IVCWA may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of IVCWA 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, IVCWA will never engage in 16  trading that operates to the client’s disadvantage if representatives of IVCWA buy or sell securities at or around the same time as clients. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on IVCWA’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 IVCWA may also consider the market expertise and research access provided by 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 IVCWA's research efforts. IVCWA will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker-dealer/custodian. IVCWA recommends Schwab Institutional, a division of Charles Schwab & Co., Inc. (“CS&Co.”) Member FINRA/SIPC. 1. Research and Other Soft-Dollar Benefits While IVCWA has no formal soft dollars program in which soft dollars are used to pay for third party services, IVCWA may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft dollar benefits”). IVCWA 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 IVCWA does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. IVCWA benefits by not having to produce or pay for the research, products or services, and IVCWA will have an incentive to recommend a broker-dealer based on receiving research or services. Clients should be aware that IVCWA’s acceptance of soft dollar benefits may result in higher commissions charged to the client. 2. Brokerage for Client Referrals IVCWA 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 17  IVCWA may permit clients to direct it to execute transactions through a specified broker-dealer. If a client directs brokerage, then the client will be required to acknowledge in writing that the client’s direction with respect to the use of brokers supersedes any authority granted to IVCWA to select brokers; this direction may result in higher commissions, which may result in a disparity between free and directed accounts; the client may be unable to participate in block trades (unless IVCWA is able to engage in “step outs”); and trades for the client and other directed accounts may be executed after trades for free accounts, which may result in less favorable prices, particularly for illiquid securities or during volatile market conditions. Not all investment advisers allow their clients to direct brokerage. B. Aggregating (Block) Trading for Multiple Client Accounts If IVCWA 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, IVCWA 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. IVCWA would determine the appropriate number of shares and select the appropriate brokers consistent with its duty to seek best execution, except for those accounts with specific brokerage direction (if any). Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for IVCWA's advisory services provided on an ongoing basis are reviewed at least Quarterly by Paul Joseph McColgan, Chief Compliance Officer, with regard to clients’ respective investment policies and risk tolerance levels. All accounts at IVCWA are assigned to this reviewer. 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). 18  C. Content and Frequency of Regular Reports Provided to Clients Each client of IVCWA'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 report will come from the custodian. IVCWA will also provide at least quarterly a separate written statement to the client. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) With respect to CS&Co., IVCWA receives access to CS&Co.’s institutional trading and custody services, which are typically not available to CS&Co. retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at CS&Co. CS&Co.’s services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For IVCWA client accounts maintained in its custody, CS&Co. generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through CS&Co. or that settle into Schwab accounts. CS&Co. also makes available to IVCWA other products and services that benefit IVCWA but may not benefit its clients’ accounts. These benefits may include national, regional or IVCWA specific educational events organized and/or sponsored by CS&Co.. Other potential benefits may include occasional business entertainment of personnel of IVCWA by CS&Co. personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist IVCWA in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of IVCWA’s fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of IVCWA’s accounts. CS&Co. also makes available to IVCWA other services intended to help IVCWA manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information 19  technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance and marketing. In addition, CS&Co. may make available, arrange and/or pay vendors for these types of services rendered to IVCWA by independent third parties. CS&Co. may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to IVCWA. IVCWA is independently owned and operated and not affiliated with CS&Co. B. Compensation to Non – Advisory Personnel for Client Referrals IVCWA does not compensate non-advisory personnel (solicitors/promoters) for client referrals. Solicitor relationships will be fully disclosed to each Client to the extent required by applicable law. IVCWA will ensure each solicitor is exempt, notice filed, or properly registered in all appropriate jurisdictions. All such referral activities will be conducted in accordance with Rule 206(4)-1 under the Advisers Act, where applicable. In cases Financial Consulting Partners act in an impersonal manner and are exempt from Rule 206(4)-1. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, IVCWA 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. Item 16: Investment Discretion in making IVCWA provides discretionary and non-discretionary investment advisory services to clients. The advisory contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, IVCWA 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 instances, IVCWA’s discretionary authority share. In some these determinations may be limited by conditions imposed by a client (in investment guidelines or objectives, or client instructions otherwise provided to IVCWA. 20  Item 17: Voting Client Securities (Proxy Voting) IVCWA will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information A. Balance Sheet IVCWA 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 IVCWA nor its management has any financial condition that is likely to reasonably impair IVCWA’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years IVCWA has not been the subject of a bankruptcy petition in the last ten years. 21