JAYKAY WEALTH ADVISORS, INC.

Jaykay Wealth Advisors, Inc. Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Jaykay Wealth Advisors, Inc. If you have any questions about the contents of this brochure, please contact us at 713-780-4575 or by email at: jay@advisorusa.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 Jaykay Wealth Advisors, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov. Jaykay Wealth Advisors, Inc.’s CRD number is: 170192. 6200 Savoy Dr., Suite # 300 Houston, Texas, 77036 713-780-4575 www.advisorusa.com Registration does not imply a certain level of skill or training. Version Date: 03/06/2025  Item 2: Material Changes The material changes made since last amendment filed by Jaykay Wealth Advisors, Inc. in June 2024 are as follows: • In May 2024 the firm updated the Financial Planning fee schedule, please refer to Item 5 – Fees and Compensation for more specific information. • In October 2024, the firm updated Item 5 to update the Fees for Retirement Plan Services and to provide more detail on the billing practices of LPL Financial and the method of calculation utilized for billing adjustments on additions or withdrawals from the account. • We have updated our assets under management. Please see item 4 – Advisory Business for additional information. In the future, this item will discuss only specific material changes that are made to the Brochure and provide clients with a summary of such changes. We will ensure that you receive a summary of any material changes to this and JKWAI Brochures within 120 days of the close of our business’ fiscal year. We may further provide other ongoing disclosure information about material changes as necessary will further provide you with a new Brochure as necessary based on changes or new information, at any time, without charge. Currently, our Disclosure Brochure may be requested by contacting us at 713-780-4575 or by email at: jay@advisorusa.com. i  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ........................................................................................................................... i Item 3: Table of Contents .......................................................................................................................... ii Item 4: Advisory Business .........................................................................................................................5 A. Description of the Advisory Firm ................................................................................................................5 B. Types of Advisory Services ...........................................................................................................................5 Portfolio Management Services .....................................................................................................................5 Financial Planning ...........................................................................................................................................6 Referral of Third-Party Money Managers ....................................................................................................6 Retirement Plan Services ................................................................................................................................6 Educational Seminars/Workshops ...............................................................................................................9 Services Limited to Specific Types of Investments ................................................................................... 10 C. Client Tailored Services and Client Imposed Restrictions ...................................................................... 10 D. Wrap Fee Programs ...................................................................................................................................... 10 E. Assets Under Management .......................................................................................................................... 10 Item 5: Fees and Compensation .............................................................................................................. 11 A. Fee Schedule .................................................................................................................................................. 11 Portfolio Management Services Fees .......................................................................................................... 11 Financial Planning Fees ................................................................................................................................ 12 Fixed Fees ....................................................................................................................................................... 12 Hourly Fees .................................................................................................................................................... 12 Fees for Third-Party Money Manager ........................................................................................................ 13 Fees for Retirement Plan Services ............................................................................................................... 14 Fees for Educational Seminars/Workshops .............................................................................................. 15 B. Payment of Fees ............................................................................................................................................. 15 Payment of Portfolio Management Fees .................................................................................................... 15 Payment of Financial Planning Fees ........................................................................................................... 15 C. Client Responsibility For Third Party Fees ............................................................................................... 16 D. Prepayment of Fees ...................................................................................................................................... 16 ii  E. Outside Compensation For the Sale of Securities to Clients ................................................................... 16 Item 6: Performance-Based Fees and Side-By-Side Management ..................................................... 17 Item 7: Types of Clients ........................................................................................................................... 17 Minimum Account Size ................................................................................................................................ 17 Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss ........................ 17 A. Methods of Analysis and Investment Strategies .................................................................................. 17 Methods of Analysis ...................................................................................................................................... 17 Investment Strategies .................................................................................................................................... 18 B. Material Risks Involved ........................................................................................................................... 18 Methods of Analysis ...................................................................................................................................... 18 Investment Strategies .................................................................................................................................... 18 C. Risks of Specific Securities Utilized ....................................................................................................... 18 Item 9: Disciplinary Information ............................................................................................................ 20 A. Criminal or Civil Actions ........................................................................................................................ 20 B. Administrative Proceedings ................................................................................................................... 20 C. Self-regulatory Organization (SRO) Proceedings ................................................................................ 21 Item 10: Other Financial Industry Activities and Affiliations ............................................................ 21 A. Registration as a Broker/Dealer or Broker/Dealer Representative .................................................. 21 B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor ................................................................................................................................................ 21 C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests 21 D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections ............................................................................................................................................................ 22 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .. 22 A. Code of Ethics ........................................................................................................................................... 22 B. Recommendations Involving Material Financial Interests ................................................................. 23 C. Investing Personal Money in the Same Securities as Clients ............................................................. 23 D. Trading Securities At/Around the Same Time as Clients’ Securities ............................................... 23 Item 12: Brokerage Practices ................................................................................................................... 23 A. Factors Used to Select Custodians and/or Broker/Dealers ............................................................... 23 B. Aggregating (Block) Trading for Multiple Client Accounts ............................................................... 26 iii  Item 13: Reviews of Accounts ................................................................................................................. 27 A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews ................................ 27 B. Factors That Will Trigger a Non-Periodic Review of Client Accounts ............................................. 27 C. Content and Frequency of Regular Reports Provided to Clients ...................................................... 27 Item 14: Client Referrals and Other Compensation ............................................................................. 27 A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) ................................................................................................................................... 27 B. Compensation to Non – Advisory Personnel for Client Referrals .................................................... 28 Item 15: Custody ....................................................................................................................................... 28 Item 16: Investment Discretion ............................................................................................................... 28 Item 17: Voting Client Securities (Proxy Voting) ................................................................................. 29 Item 18: Financial Information ................................................................................................................ 29 A. Balance Sheet ............................................................................................................................................. 29 B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients .................................................................................................................................................................. 29 C. Bankruptcy Petitions in Previous Ten Years ........................................................................................ 30 iv  Item 4: Advisory Business A. Description of the Advisory Firm Jaykay Wealth Advisors, Inc. (hereinafter “JKWAI”) is a Corporation organized in the State of Texas. The firm was formed in December 2003, and the principal owners are Jayanth Kabad, Kanchan Kabad and Anasuya Kabad Meyer. In 2018 the firm reached the level of assets under management where it changed its primary regulatory authority to the U.S. Securities and Exchange Commission. B. Types of Advisory Services JKWAI offers the following services to advisory clients: Portfolio Management Services JKWAI offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. 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 JKWAI evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. JKWAI will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. JKWAI seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of JKWAI’s economic, investment or other financial interests. To meet its fiduciary obligations, JKWAI attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and, accordingly, JKWAI’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 JKWAI’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent that might have a limited supply, among its clients on a fair and equitable basis over time. 5  Financial Planning Financial plans and financial planning may include but are not limited to business planning, investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Referral of Third-Party Money Managers SEI Asset Management Program The SEI Asset Management Program (SEI Program) is an institutional asset allocation program that JKWAI uses in the management of assets for client accounts. If you enroll in the SEI Asset Management Program, JKWAI will assist you in the establishment of a SEI Program Account (the Account) at SEI Private Trust Company (SEI). All Account transactions are processed and cleared through SEI. The SEI Program uses asset allocation portfolios developed by SEI Investments. The portfolios consist of SEI Family of Institutional Mutual Funds (Mutual Funds) and other securities approved by SEI to be held in an account. The SEI Program uses the Portfolio Managers selected and subject to oversight by SEI and who have entered into a sub- advisory agreement with SEI. JKWAI will provide SEI with the asset allocation policy that you select for your account. JKWAI will direct SEI to reallocate your investments in accordance with your Asset Allocation Policy. In addition, based on JKWAI instructions, SEI will rebalance the investments within your account at least annually so that the market value of the shares of each mutual fund held in your account is the same percentage of the total market value of your account as required by your Asset Allocation Policy. SEI and its Portfolio Managers will have discretionary authority over the assets and transactions in the Account. JKWAI will have discretionary authority to re- allocate your portfolios among the various Portfolio Managers as needed. SEI has the authority to replace a previously selected Portfolio Manager or SEI Fund without your prior approval. Custody of all SEI Program Client Account assets is held at SEI Private Trust Company. Retirement Plan Services JKWAI offers retirement plan services to retirement plan sponsors and to individual participants in retirement plans. For a corporate sponsor of a retirement plan, our retirement plan services can include, but are not limited to, the following services: Fiduciary Consulting Services JKWAI provides the following Fiduciary Retirement Plan Consulting Services: 6  • Non-Discretionary Investment Advice. JKWAI will provide you with general, non- discretionary investment advice regarding assets classes and investment options, consistent with your Plan’s investment policy statement. • Investment Selection Services. JKWAI will provide you with recommendations of investment options consistent with ERISA section 404(c). • Investment Due Diligence Review. JKWAI will provide you with periodic due diligence reviews of the Plan’s reports, investment options and recommendations. • Investment Monitoring. JKWAI will assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformation to the guidelines set forth in the investment policy statement and JKWAI will make recommendations to maintain or remove and replace investment options. • Default Investment Alternative Advice. JKWAI will provide you with non-discretionary investment advice to assist you with the development of qualified default investment alternative(s) (“QDIA”), as defined in DOL Reg. Section 2550.404c-5(e)(4)(i), for participants who are automatically enrolled in the Plan or who otherwise fail to make an investment election. You will retain the sole responsibility to provide all notices to participants required under ERISA section 404(c)(5). • Individualized Participant Advice. Upon request, JKWAI will provide one-on-one advice to Plan participants regarding their individual situations. For Fiduciary Consulting Services, all recommendations of investment options and portfolios will be submitted to you for your ultimate approval or rejection. For retirement plan Fiduciary Consulting Services, the retirement plan sponsor client or the plan participant who elects to implement any recommendations made by us is solely responsible for implementing all transactions. Fiduciary Consulting Services are not management services, and JKWAI does not serve as administrator or trustee of the plan. JKWAI does not act as custodian for any client account or have access to client funds or securities (with the exception of, some accounts, having written authorization from the client to deduct our fees). JKWAI acknowledges that in performing the Fiduciary Consulting Services listed above that it is acting as a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of Employee Retirement Income Security Act of 1974 (“ERISA”) for purposes of providing non-discretionary investment advice only. JKWAI will act in a manner consistent with the requirements of a fiduciary under ERISA if, based upon the facts and circumstances, such services cause JKWAI to be a fiduciary as a matter of law. However, in providing the Fiduciary Consulting Services, JKWAI (a) has no responsibility and will not (i) exercise any discretionary authority or 7  discretionary control respecting management of Client’s retirement plan, (ii) exercise any authority or control respecting management or disposition of assets of Client’s retirement plan, or (iii) have any discretionary authority or discretionary responsibility in the administration of Client’s retirement plan or the interpretation of Client’s retirement plan documents, (b) is not an “investment manager” as defined in Section 3(38) of ERISA and does not have the power to manage, acquire or dispose of any plan assets, and (c) is not the “Administrator” of Client’s retirement plan as defined in ERISA. Non-Fiduciary Services Although an investment adviser is considered a fiduciary under the Investment Advisers Act of 1940 and required to meet the fiduciary duties as defined by the Advisers Act, the services listed here as non-fiduciary should not be considered fiduciary services for the purposes of ERISA since Advisor is not acting as a fiduciary to the Plan as the term “fiduciary” is defined in Section 3(21)(A)(ii) of ERISA. The exact suite of services provided to a client will be listed and detailed in the Qualified Retirement Plan Agreement. JKWAI provides clients with the following Non-Fiduciary Retirement Plan Consulting Services: • Participant Education. JKWAI will provide education services to Plan participants about general investment principles and the investment alternatives available under the Plan. JKWAI’s assistance in participant investment education will be consistent with and within the scope of DOL Interpretive Bulletin 96-1. Education presentations will not take into account the individual circumstances of each participant and individual recommendations will not be provided unless otherwise agreed upon. Plan participants are responsible for implementing transactions in their own accounts. • Participant Enrollment. JKWAI will assist you with group enrollment meetings designed to increase retirement plan participation among employees and investment and financial understanding by the employees. • Qualified Plan Development. JKWAI will assist you with the establishment of a qualified plan by working with you and a selected Third Party Administrator. If you have not already selected a Third Party Administrator, we shall assist you with the review and selection of a Third Party Administrator for the Plan. • Due Diligence Review. JKWAI will provide you with periodic due diligence reviews of your Plan’s fees and expenses and your Plan’s service providers. • Benchmarking. JKWAI will provide you benchmarking services and will provide analysis concerning the operations of the Plan. Securities and other types of investments all bear different types and levels of risk. Those risks are typically discussed with clients in defining the investment policies and objectives that will 8  guide investment decisions for their qualified plan accounts. Upon request, as part of our retirement plan services, we can discuss those investments and investment strategies that we believe may tend to reduce these risks for a particular client’s circumstances and plan participants. Clients and plan participants must realize that obtaining higher rates of return on investments entails accepting higher levels of risk. Based upon discussions with the client, we will attempt to identify the balance of risks and rewards that is appropriate and comfortable for the client and other employees. It is still the clients’ responsibility to ask questions if the client does not fully understand the risks associated with any investment. All plan participants are strongly encouraged to read prospectuses, when applicable, and ask questions prior to investing. We strive to render our best judgment for clients. Still, JKWAI cannot assure that investments will be profitable or assure that no losses will occur in their portfolios. Past performance is an important consideration with respect to any investment or investment advisor, but it is not necessarily an accurate predictor of future performance. JKWAI will disclose, to the extent required by ERISA Regulation Section 2550.408b-2(c), to you any change to the information that we are required to disclose under ERISA Regulation Section 2550.408b-2(c)(1)(iv) as soon as practicable, but no later than sixty (60) days from the date on which we are informed of the change (unless such disclosure is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclose as soon as practicable). In accordance with ERISA Regulation Section 2550.408b-2(c)(vi)(A), we will disclose within thirty (30) days following receipt of a written request from the responsible plan fiduciary or Plan Administrator (unless such disclose is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclosed as soon as practicable) all information related to the Qualified Retirement Plan Agreement and any compensation or fees received in connection with the Agreement that is required for the Plan to comply with the reporting and disclosure requirements of Title 1 of ERISA and the regulations, forms and schedules issued thereunder. If we make an unintentional error or omission in disclosing the information required under ERISA Regulation Section 2550.408b-2(c)(1)(iv) or (vi), we will disclose to you the correct information as soon as practicable, but no later than thirty (30) days from the date on which we learns of such error or omission. Educational Seminars/Workshops JKWAI occasionally provides seminars/workshops in areas such as financial planning, retirement planning, estate planning, college planning and charitable planning or other relevant 9  financial topics. Seminars/ workshops are always offered on an impersonal basis and do not focus on the individual needs of participants. Services Limited to Specific Types of Investments JKWAI generally limits its investment advice to mutual funds, equities, fixed income securities, real estate funds, real estate investment trusts (REITs), Business Development Companies, insurance products including annuities, private placements and hedge funds. JKWAI may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions JKWAI offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client’s current situation (income, tax levels, and risk tolerance levels, etc.). 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 JKWAI from properly servicing the client account, or if the restrictions would require JKWAI to deviate from its standard suite of services, JKWAI reserves the right to end the relationship. D. Wrap Fee Programs JKWAI offer services exclusively through wrap fee programs. A wrap fee program is defined as any advisory program under which a specified fee or fees not based directly upon transactions in a client’s account is charged for investment advisory services (which may include portfolio management or advice concerning the selection of other investment advisers) and the execution of client transactions. Whenever a fee is charged to a client for services described in this brochure, JKWAI will receive all or a portion of the fee charged. E. Assets Under Management JKWAI has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 170,544,786 0 01/01/2025 10  Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Services Fees JKWAI will not be compensated on the basis of a share of capital gains upon or capital appreciation of the funds or any portion of the funds of Client. JKWAI is compensated based on percentage of assets under management. Fees for accounts offered through various platforms may differ. Householding: All accounts with a shared address will be considered a household provided the average account size of the household is at least $1 Million. In calculating the fees, the assets of the grouped accounts in a household will be combined to determine the total fee. The following are the fees charged by Jaykay Wealth Advisors, Inc. for services provided: Total Assets Under Advisement Annual Fee Up to $500,000 1.50% $500,001 to $1,000,000 1.20% $1,000,001 to $3,000,000 1.00% $3,000,001 to $5,000,000 0.80% $5,000,001 to $7,000,000 0.70% $7,000,001 to $10,000,000 0.60% $10,000,001 to $15,000,000 0.55% $15,000,001 to $20,000,000 0.50% $20,000,001 to $25,000,000 0.45% $25,000,001 to $30,000,000 0.40% $30,000,001 and above 0.35 % Fees charged for our asset management services are negotiable based on the type of client, the complexity of the client's situation, the composition of the client's account i.e., equities versus 11  mutual funds, retirement or non-retirement assets, asset additions or asset distributions, the potential for additional account deposits, the relationship of the client with the investment adviser representative, and the total amount of assets under management for the client. The final fee to be charged to the client account will be included in Exhibit I of the Investment Management Agreement. Clients can choose how to pay your investment advisory fees. The investment advisory fees can be deducted from their account and paid directly to our firm by the qualified custodian(s) of their account or clients will have the option to pay our firm or the qualified custodian upon receipt of a billing notice sent directly to you. If you choose to have the investment advisory fees deducted from your account, you must authorize the qualified custodian(s) of your account to deduct fees from your account and pay such fees directly to JKWAI. Clients may terminate the agreement without penalty, for full refund of JKWAI’s fees, within five business days of signing the Investment Management Agreement. Thereafter, clients may terminate the Investment Management Agreement with thirty days’ written notice. Clients are responsible for the payment of all third-party fees (i.e. custodian fees, brokerage fees, mutual fund fees, separate manager fees, transactions fees, etc.). These fees are separate from and distinct from the fees and expenses charged by JKWAI. Fees charged by JKWAI may be withdrawn from accounts or billed separately by the third party (i.e. custodian) or JKWAI and based on billing schedule of the third party (i.e. custodian). Financial Planning Fees Clients may terminate the agreement without penalty, for full refund of JKWAI’s fees, within five business days of signing the Financial Planning Agreement. Thereafter, clients may terminate the Financial Planning Agreement with upon written notice. Fixed Fees The rate for creating client financial plans is between $1,500 and $100,000. The fees are negotiable, and the final fee schedule will be attached as Exhibit II of the Financial Planning Agreement. Hourly Fees The hourly rate for creating client financial plans is $250 per hour. The fees are negotiable, and the final fee schedule will be attached as Exhibit II of the Financial Planning Agreement. 12  Fees for Third-Party Money Manager SEI Asset Management Program JKWAI offers third party asset management services through the SEI Program. Clients enter into a Tri-Party Agreement between the client, JKWAI, and SEI. JKWAI and SEI act as co- advisors in the Tri-Party Agreement. JKWAI has discretion to move the client assets between SEI portfolio strategies. Clients in the SEI Program will pay JKWAI a maximum Advisory Fee of 1.5% based on assets under management. The fee charged by SEI will be disclosed in the Tri-Party agreement between JKWAI, SEI and you. The custody of all funds and securities are maintained by SEI. SEI Trust Company may charge a separate custodial fee for the custody services it provides to your account. A complete description of SEI’s advisory services, fee schedules and account minimums will be disclosed in their Firm Brochure which will be provided to you by SEI prior to or at the time an agreement for services is executed and the account is established. SEI earns fees in one of three ways for the services it provides. 1. SEI mutual funds have internal expenses. SEI receives the internal expenses related to the SEI mutual fund offerings. 2. SEI provides strategic asset management solutions. SEI charges for these asset management services. 3. SEI provides a platform to support advisers and client services and custodian services. Each quarter, SEI sends you an account statement that includes details of the fees charged to your account. SEI Program Management Fees (management fees) are payable quarterly, in arrears, net of income, withholding or other taxes, based on assets under management at the end of the quarter. Management Fees are automatically deducted from your account. Each quarter, SEI sends you an account statement that includes a management fee notification which shows the computed fee, any adjustments to the fee, an explanation of any adjustment and the net management fee to be deducted later in the period from your account. Management fees are paid to JKWAI. You may terminate the SEI Program Account at any time by notifying JKWAI. Termination will be effective upon 30 days written notice to the other party. If services are terminated within five business days of executing the client agreement, services will be terminated without penalty. After the initial five business days, you may be responsible for payment of fees for the number of days services were provided by JKWAI prior to receipt of the notice of termination. 13  JKWAI may invest a portion of your assets in mutual funds, exchange traded funds (ETFs) or other approved investments that are managed by SEI. These products charge an investment management fee on client’s assets invested in these securities. If you are invested in a SEI mutual fund, SEI is paid an investment management fee by the mutual fund, therefore, SEI will not charge a custodian fee. LPL Financial Advisory clients who have accounts at LPL Financial pay an Account Fee based on the value of the assets in the account as of the close of business on the last business day of the preceding quarter. The account fee is payable quarterly in advance – per the fee cycle established when the account is opened. For accounts under the Strategic Wealth Management Program “SWM”, the initial Account Fee is due at the beginning of the quarter following account inception and will be the prorated fee for the initial quarter in addition to the standard quarterly fee for the upcoming quarter. For accounts under the Managed Account Solutions Program “MAS”, the initial account fee is due on the account inception date and will be prorated from the date of inception through the remaining current cycle 3 quarter (March/June/September/December). In regards to the standard quarterly fee, Advance billing is done on a quarterly basis and is the primary way Account Fees are assessed to advisory accounts. It is calculated as follows - [Quarter End Value X Advisory Account Fee] / 360 X 90 For all accounts at LPL Financial, additional deposits and withdrawals will be added or subtracted from portfolio assets on a prorated basis to adjust the account fee. Quarterly billing adjustments account for any deposits or withdrawals made during the quarter. This is to ensure that the client is being charged only for the time the assets have resided in the account. To calculate the billing adjustments, the number of days each deposit and withdrawal was in the account must be determined. It is calculated in the following way – [Deposit or Withdrawal X Advisory Account Fee] / 360 X Prorated Dates = Billing Adjustment Fees for Retirement Plan Services For retirement plan sponsor clients, JKWAI will charge an annual fee that is calculated as a percentage of the value of plan assets. This fee is negotiable based upon the complexity of the plan, the size of the plan assets, the actual services requested and the potential for additional deposits. 14  If JKWAI charges an annual fee based upon the value of the plan assets, we charge an annual fee of up to 0.50%. For retirement plan sponsors fees are billed in advance (at the start of the billing period) on a quarterly calendar basis and calculated based on the fair market value of your account as of the last business day of the previous billing period. Fees are prorated (based on the number of days service is provided during the initial billing period) for your account opened at any time other than the beginning of the billing period. Fee invoices will be sent directly to the Plan and are due upon receipt of the billing notice. The services will terminate upon thirty (30) days following either party providing the other party with written notice. If services are terminated within five business days of signing the client agreement, services are terminated without penalty. Any prepaid but unearned fees are promptly refunded to the client at the effective date of termination. JKWAI does not reasonably expect to receive any other compensation, direct or indirect, for its Services. If we receive any other compensation for such services, we will (i) offset that compensation against our stated fees, and (ii) will disclose the amount of such compensation, the services rendered for such compensation and the payer of such compensation to you. Fees for Educational Seminars/Workshops No fees are charged to attend our seminars or workshops. B. Payment of Fees Payment of Portfolio Management Fees Portfolio management fees are withdrawn directly from the client’s accounts with client’s written authorization or may be invoiced and billed directly to the client; clients may select the method in which they are billed. Fees are paid quarterly. Payment of Financial Planning Fees Fixed or Hourly Financial Planning fees are paid via check or by credit card or electronic funds transfer through the AdvicePay billing system. Please note that the billing system, Advice Pay, may charge additional fees for processing. 15  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 JKWAI. Please see Item 12 of this brochure regarding broker/custodian. D. Prepayment of Fees JKWAI collects its fees in arrears and in advance. Managed accounts held at LPL and Schwab are billed in advance. Managed Account held at SEI are billed in arears. Refunds for fees paid in advance will be returned within fourteen days to the client via check or return deposit back into the client’s account. For all asset-based fees paid in advance, the fee refunded will be the balance of the fees collected in advance minus the daily rate* times the number of days in the billing period up to and including the day of termination. (*The daily rate is calculated by dividing the annual asset-based fee by 365.) E. Outside Compensation For the Sale of Securities to Clients Jayanth R. Kabad and Anasuya Kabad Meyer are registered representatives of LPL Financial and accept compensation for the sale of securities to JKWAI clients. 1. This is a Conflict of Interest The supervised persons will accept compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds to its 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 securities or investment products for which the supervised persons receives compensation, they will document the conflict of interest in the client file and inform the client of the conflict of interest. 2. Clients Have the Option to Purchase Recommended Products From Other Brokers Clients always have the option to purchase JKWAI recommended products through other brokers or agents that are not affiliated with JKWAI. 3. Commissions are not the Primary Source of Income for JKWAI 16  Commissions are not JKWAI’s primary source of compensation. 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 securities or investment products recommended to clients. Item 6: Performance-Based Fees and Side-By-Side Management JKWAI 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 JKWAI generally provides advisory services to the following types of clients:  Individuals  High-Net-Worth Individuals  Charitable Organizations Minimum Account Size The minimum account size required to establish an account with JKWAI is $ 1,000,000. To reach this minimum, clients can aggregate all household accounts. However, JKWAI may waive this requirement under certain circumstances. The minimum fixed fee generally charged for financial planning services on a fixed fee basis is $1,500. The minimum hourly fee generally charged for financial planning and consulting services is $250. Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss A. Methods of Analysis and Investment Strategies Methods of Analysis JKWAI’s methods of analysis include modern portfolio theory. 17  Modern portfolio theory is a theory of investment which attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, by carefully choosing the proportions of various assets. Investment Strategies JKWAI uses long term trading. 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 Modern Portfolio Theory assumes that investors are risk adverse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk- expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Investment 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. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. 18  They can be of bond “fixed income” nature (lower risk) or stock “equity” nature (mentioned below). Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and 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 market conditions and general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary and 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. Real Estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Private placements carry a substantial risk as they are subject to less regulation that publicly offered securities, the market to resell these assets under applicable securities laws may be illiquid, due to restrictions, and liquidation may be taken at a substantial discount to the underlying value or result in the entire loss of the value of such assets. Annuity Risk • Costs and Fees – Annuities are one of the most expensive types of investments available in the financial marketplace. 19  • Illiquid Investment – Most annuity contracts charge stiff surrender penalties for early withdrawal, plus a 10% premature distribution penalty to investors who take withdrawals before age 59½. • Economic Risks: Most fixed annuities do not contain a cost of living adjustment clause. Consequently, the spending power provided by the monthly payment may decline significantly over the life of the annuity contract because of inflation. Annuities with inflation protection are available, but they are significantly more expensive. • Death and survivorship risk. In a conventional fixed annuity, once the annuitant has turned over a lump sum premium to the insurance company, it will not be returned. The annuitant could die after receiving only a few monthly payments, but the insurance company may not be obligated to give the annuitant’s estate any of the money back. A related risk is based on the financial consequences for a surviving spouse. In a standard single-life annuity contract, a survivor receives nothing after the annuitant dies. That may put a severe dent in a spouse’s retirement income. To counteract this risk, consider a joint life annuity. • Company failure risk. All investments carry a level of risk. Make sure you consider the financial strength of the insurance company issuing the annuity. You want to be sure the company will still be around, and financially sound, during your payout phase. Private annuity contracts are not guaranteed by the FDIC, SIPC, or any other federal agency. If the insurance company that issues an annuity contract fails, no one in the federal government is obligated to protect the annuitant from financial loss. Most states have guaranty associations that provide a level of protection to citizens in that state if an insurance company also doing business in that state fails. A typical limit of state protection, if it applies at all, is $100,000. • Taxation Risk: All withdrawals received from an annuity contract that are not considered to be a return of principal are taxed as ordinary income, regardless of the holding period of the contract. There is no chance to qualify for capital gains treatment. 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 20  There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Jayanth R. Kabad and Anasuya Kabad Meyer are registered representatives of LPL Financial. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither JKWAI 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 Jayanth R. Kabad and Anasuya Kabad Meyer are registered representatives of LPL Financial. From time to time, they 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. JKWAI always acts in the best interest of the client, including with respect to the sale of commissionable products to advisory clients. Clients are in no way required to purchase such services or products through any representative of JKWAI in such individual’s outside capacities. As discussed previously, Jayanth R. Kabad and Anasuya Kabad Meyer are registered representatives of LPL Financial. As a result of this relationship, LPL Financial may have access to certain confidential information (e.g., financial information, investment objectives, transactions and holdings) about JKWAI's clients, even if client does not establish any account through LPL. If you would like a copy of the LPL Financial privacy policy, please contact us at 713-780-4575. Jayanth Rao Kabad and Anasuya Kabad Meyer are licensed insurance agents, but only Jayanth Rao Kabad and Anasuya Kabad Meyer currently work in the profession. From time to time, they will offer clients advice or products from this activity through LPL insurance associates or 21  other insurance brokerages. Clients should be aware that these services pay a commission and involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of a registered investment adviser. JKWAI always acts in the best interest of the client, including in the sale of commissionable products to advisory clients. Clients are in no way required to utilize the services of any representative of JKWAI in their capacity as a licensed insurance agent. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections JKWAI Planning utilizes the SEI Asset Management Platform, previously described in Item 5 of this disclosure brochure, designed to allow us to select third-party money managers for you. Once your assets are placed with a third-party money manager on the SEI Platform, SEI will pay us a portion of the Advisory Fees you are charged. Receiving direct or indirect compensation for the management of assets by third-party asset managers creates a material conflict of interest, because JKWAI has an incentive to place assets based on compensation. JKWAI addresses this material conflict of interest through a process of placing assets solely on the suitability information provided by the client and documented on account applications. The investment advisor representative will monitor the client’s investments, and whether or not those investments are reflective of the risk tolerance, time horizon, and investment objective of the account. Please refer to Items 4 and 5 for full details regarding the programs. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics JKWAI 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. Our Code of Ethics is available free upon request to any client or prospective client. 22  B. Recommendations Involving Material Financial Interests JKWAI does not recommend that clients buy or sell any security in which a related person to JKWAI or JKWAI has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of JKWAI may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of JKWAI 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. JKWAI 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 JKWAI may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of JKWAI 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, JKWAI will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers 1. Research and Other Soft-Dollar Benefits LPL Financial, LLC. While JKWAI has no formal soft dollar program in which soft dollars are used to pay for third party services, JKWAI does receive support services and/or products from LPL Financial, many of which assist the JKWAI to better monitor and service program accounts maintained at LPL Financial; however, some of the services and products benefit JKWAI and not client accounts. These support services and/or products may be received without cost, at a discount, and/or at a negotiated rate, and may include the following: 23  investment-related research software and other technology that provide access to client account data compliance and/or practice management-related publications consulting services computer hardware and/or software • • pricing information and market data • • • • attendance at conferences, meetings, and other educational and/or social events • marketing support • • other products and services used by JKWAI in furtherance of its investment advisory business operations LPL Financial may provide these services and products directly or may arrange for third party vendors to provide the services or products to Advisor. In the case of third-party vendors, LPL Financial may pay for some or all of the third party’s fees. These support services are provided to JKWAI based on the overall relationship between JKWAI and LPL Financial. It is not the result of soft dollar arrangements or any other express arrangements with LPL Financial that involves the execution of client transactions as a condition to the receipt of services. JKWAI will continue to receive the services regardless of the volume of client transactions executed with LPL Financial. Clients do not pay more for services as a result of this arrangement. There is no corresponding commitment made by the JKWAI to LPL or any other entity to invest any specific amount or percentage of client assets in any specific securities as a result of the arrangement. However, because Advisor receives these benefits from LPL Financial, there is a potential conflict of interest. The receipt of these products and services presents a financial incentive for Advisor to recommend that its clients use LPL Financial’s custodial platform rather than another custodian’s platform. Charles Schwab JKWAI may recommend/require that clients establish brokerage accounts with the Schwab Institutional division of Charles Schwab & Co., Inc (“Schwab”), a FINRA-registered broker- dealer, Member SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. Although JKWAI may recommend/require the clients establish accounts at Schwab, it is the client’s decision to custody assets with Schwab. JKWAI is independently owned and operated and not affiliated with Schwab. JKWAI may recommend additional unaffiliated broker-dealers to affect fixed income transactions. Effective October 7, 2019, Schwab has eliminated commissions for online trades of U.S. equities, ETFs and options (subject to $0.65 per contract fee). We encourage you to review Schwab’s pricing to compare the total costs of entering into a wrap fee arrangement versus a non-wrap arrangement. You will still incur commissions and fees for certain types of transactions in a 24  non-wrap fee arrangement. To see what you would pay for transactions in a non-wrap account please refer to Schwab’s most recent pricing schedules available at www.schwab.com/aspricingguide. Schwab provides JKWAI with access to its institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the advisor’s clients’ assets are maintained at Schwab Institutional. These services are not contingent upon JKWAI committing to Schwab any specific amount of business (assets in custody or trading commissions). Schwab’s brokerage services include the execution of securities transactions, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require significantly higher minimum initial investment. Schwab Institutional also makes available to JKWAI other products are services that benefit JKWAI but may not directly benefit clients’ accounts. Many of these products and services may be used to service all or some substantial number of JKWAI’ accounts, including accounts not maintained Schwab. Schwab’s products and services that assist JKWAI in managing and administering clients’ accounts include software and other technology that (i) provides access to client account data (such as trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade orders for multiple client accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment of JKWAI’s fees from some of its accounts; and (v) assist with back-office functions, recordkeeping and client reporting. Schwab Institutional also offers other services intended to help JKWAI manage and further develop its business enterprise. These services may include: (i) compliance, legal and business consulting; (ii) publications and conferences on practice management and business succession; and (iii) access to employee benefits providers, human capital consultants and insurance providers. Schwab Institutional may discount or waive fees it would otherwise charge for some of these services or pay all or part of the fees of a third-party providing these services to JKWAI. Schwab Institutional may also provide other benefits such as educational events or occasional business entertainment of JKWAI personnel. While as a fiduciary, JKWAI endeavors to act in its clients’ best interests, JKWAI’s recommendation that clients maintain their assets in accounts at Schwab may take into account availability of some of the foregoing products and services and other arrangements not solely on the nature of cost or quality of custody and brokerage services provided by Schwab, which may create a conflict of interest. SEI Trust Company 25  SEI Trust provides JKWAI with access to their institutional trading and custody services. The services from SEI Trust include brokerage, custody, research and access to mutual funds and other investments. SEI Trust is the custodian that supports the SEI Asset Management program. A complete description of SEI’s advisory services, fee schedules and account minimums will be disclosed in their Firm Brochure which will be provided to you by SEI prior to or at the time an agreement for services is executed and the account is established. 2. Brokerage for Client Referrals JKWAI 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 JKWAI typically requires clients to use either LPL Financial LLC, Charles Schwab or SEI Investment Company, to execute transactions. B. Aggregating (Block) Trading for Multiple Client Accounts JKWAI may elect to purchase or sell the same securities for several clients at approximately the same time. This process is referred to as aggregating orders, batch trading or block trading and is used by JKWAI when it is believed such action may prove advantageous to clients. If and when we aggregate client orders, allocating securities among client accounts is done on a fair and equitable basis. Typically, the process of aggregating client orders is done in order to achieve better execution, to negotiate more favorable commission rates or to allocate orders among clients on a more equitable basis in order to avoid differences in prices and transaction fees or other transaction costs that might be obtained when orders are placed independently. JKWAI uses the average price allocation method for transaction allocation. Under this procedure JKWAI will calculate the average price and transaction charges for each transaction included in a block order and assign the average price and transaction charge to each allocated transaction executed for the client’s account. If and when we determine to aggregate client orders for the purchase or sale of securities, including securities in which JKWAI or our associated persons may invest, we will do so in accordance with the parameters set forth in the SEC No-Action Letter, SMC Capital, Inc. Neither JKWAI nor our associated persons receive any additional compensation as a result of block trades. 26  Item 13: Reviews of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client portfolio management accounts are reviewed at least annually by Jayanth Kabad or Anasuya Kabad Meyer with regard to clients’ respective investment policies and risk tolerance levels. All financial planning accounts are reviewed upon financial plan creation and plan delivery by Jayanth Kabad or Anasuya Kabad Meyer. There is only one level of review for financial plans, and that is the total review conducted to create the financial plan. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Portfolio management reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). With respect to financial plans, JKWAI’s services will generally conclude upon delivery of the financial plan. C. Content and Frequency of Regular Reports Provided to Clients Each portfolio management client will receive at least quarterly a written report that details the client’s account including assets held and asset value, which report will come from the custodian and at least annually a written report from JKWAI. Each financial planning client will receive the financial plan upon completion. 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) JKWAI receives an economic benefit from Schwab in the form of the support products and services it makes available to me and other independent investment advisers whose clients maintain their accounts at Schwab. These products and services, how they benefit us, and the related conflicts of interest are described above (see Item 12 – Brokerage Practices). The 27  availability of Schwab’s products and services is not based on me giving particular investment advice, such as buying particular securities for my clients. We may from time to time receive expense reimbursement for travel and/or marketing expenses from distributors of investment and/or insurance products. Travel expense reimbursements are typically a result of attendance at due diligence and/or investment training events hosted by product sponsors. Marketing expense reimbursements are typically the result of informal expense sharing arrangements in which product sponsors may underwrite costs incurred for marketing such as client appreciation events, advertising, publishing, and seminar expenses. Although receipt of these travel and marketing expense reimbursements are not predicated upon specific sales quotas, the product sponsor reimbursements are typically made by those sponsors for whom sales have been made or it is anticipated sales will be made. This creates a conflict of interest in that there is an incentive to recommend certain products and investments based on the receipt of this compensation instead of what is in the best interest of our clients. We attempt to control for this conflict by always basing investment decisions on the individual needs of our clients. B. Compensation to Non – Advisory Personnel for Client Referrals JKWAI does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Item 15: Custody When it deducts fees directly from client accounts at a selected custodian, JKWAI 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 JKWAI provides discretionary investment advisory services to clients. The Investment Management Agreement established with each client outlines the discretionary authority for trading. Where investment discretion has been granted, JKWAI generally manages the client’s account and makes investment decisions without consultation with the client as to what securities to buy or sell, when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, or the price per share. In some instances, JKWAI’s discretionary authority in making these determinations may be limited by conditions imposed 28  by a client (in investment guidelines or objectives, or client instructions otherwise provided to JKWAI.) SEI Program Discretion Client will grant JKWAI discretionary authority (without first consulting with Client) to establish and/or terminate a relationship with a Portfolio Manager within the SEI Platform for purposes of managing the Account or a portion of the Account determined by JKWAI. Client will also grant the Portfolio Manager selected by JKWAI with the discretionary authority (in the sole discretion of the Portfolio Manager without first consulting with Client) to make all decisions to buy, sell or hold securities, cash or other investments for such portion of the Account managed by the Portfolio Manager. Client will also grant the Portfolio Manager selected by JKWAI with the power and authority to carry out these decisions by giving instructions, on behalf of Client, to brokers and dealers and the qualified custodian(s) of the Account. Client authorizes JKWAI to provide a copy of this Agreement to the qualified custodian or any broker or dealer, through which transactions will be implemented on behalf of Client, as evidence of Portfolio Manager’s authority under this Agreement. Item 17: Voting Client Securities (Proxy Voting) JKWAI 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 JKWAI neither requires nor solicits prepayment of more than $1200 in fees per client, six months or more in advance and therefore does not need to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither JKWAI nor its management has any financial condition that is likely to reasonably impair JKWAI’s ability to meet contractual commitments to clients. 29  C. Bankruptcy Petitions in Previous Ten Years JKWAI has not been the subject of a bankruptcy petition in the last ten years. 30 

Item 1 – Cover Page Part 2A Appendix 1 Wrap Fee Program Brochure Jaykay Wealth Advisors, Inc 6200 Savoy Dr., Suite # 300 Houston, TX 77036 713-780-4575 www.advisorusa.com Date of Disclosure Brochure: March 2025 ____________________________________________________________________________________ This Wrap Fee Program Brochure provides information about the qualifications and business practices of Jaykay Wealth Advisors, Inc (also referred to as we, us and JKWAI throughout this disclosure brochure). If you have any questions about the contents of this brochure, please contact 713-780-4575 or by email at: jay@advisorusa.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 Jaykay Wealth Advisors is also available on the Internet at www.adviserinfo.sec.gov. You can view our firm’s information on this website by searching for Jaykay Wealth Advisors, Inc or our firm’s CRD number 170192. *Registration as an investment adviser does not imply a certain level of skill or training. Jaykay Wealth Advisors, Inc Page 1 Form ADV Part 2A Appendix 1  Item 2 – Material Changes The material changes made since last amendment filed by Jaykay Wealth Advisors, Inc. in June 2024 are as follows: • In October 2024, the firm updated Item 4 to provide more detail on the billing practices of LPL Financial and the method of calculation utilized for billing adjustments on additions or withdrawals from the account. We will ensure that you receive a summary of any material changes to this and subsequent Wrap Fee Program Disclosure Brochures within 120 days after our firm’s fiscal year ends. Our firm’s fiscal year ends on December 31, so you will receive the summary of material changes no later than April 30 each year. At that time, we will also offer or provide a copy of the most current Wrap Fee Program Disclosure Brochure. We may also provide other ongoing disclosure information about material changes as necessary. Jaykay Wealth Advisors, Inc Page 2 Form ADV Part 2A Appendix 1  Item 3 – Table of Contents Item 1 – Cover Page ...................................................................................................................................... 1 Item 2 – Material Changes ............................................................................................................................ 2 Item 3 – Table of Contents ............................................................................................................................. 3 Item 4 – Services, Fees and Compensation ................................................................................................... 4 Block Trading ............................................................................................................................................ 8 Suitability and Investment Strategy ........................................................................................................... 8 Additional Compensation, Economic and Non-Economic Benefits .......................................................... 8 Item 5 – Account Requirements and Types of Clients ................................................................................ 10 Minimum Account Size ............................................................................................................................ 10 Types of Accounts ................................................................................................................................... 10 Item 6 – Portfolio Manager Selection and Evaluation ................................................................................. 10 Participation in Wrap Fee Programs ....................................................................................................... 10 General Description of Other Advisory Services ..................................................................................... 11 Fiduciary Consulting Services ................................................................................................................. 12 JKWAI provides the following Fiduciary Retirement Plan Consulting Services: ..................................... 12 Educational Seminars/Workshops ..................................................................................................... 15 Limits Advice to Certain Types of Investments ....................................................................................... 16 Tailor Advisory Services to Individual Needs of Clients .......................................................................... 16 Performance-Based Fees and Side-By-Side Management .................................................................... 16 Methods of Analysis ................................................................................................................................ 17 Investment Strategies ............................................................................................................................. 17 Risk of Loss ............................................................................................................................................. 17 Voting Client Securities ........................................................................................................................... 18 Item 7 – Client Information Provided to Portfolio Managers ..................................................................... 19 Item 8 - Client Contact with Portfolio Managers ........................................................................................ 19 Item 9 - Additional Information .................................................................................................................. 19 Disciplinary Information ........................................................................................................................... 19 Other Financial Industry Activities and Affiliations .................................................................................. 19 Registered Representative of a Broker-Dealer ....................................................................................... 20 Insurance Agent ...................................................................................................................................... 21 Interest in Client Transactions and Code of Ethics ................................................................................. 21 Affiliate and Employee Personal Securities Transactions Disclosure..................................................... 22 Account Reviews ..................................................................................................................................... 23 Account Statements and Reports ........................................................................................................... 23 Client Referrals ....................................................................................................................................... 23 Financial Information ............................................................................................................................... 23 Jaykay Wealth Advisors, Inc Page 3 Form ADV Part 2A Appendix 1  Item 4 – Services, Fees and Compensation JKWAI is an investment adviser registered with the United States Securities and Exchange Commission (“SEC”) and is a corporation formed under the laws of the State of Texas. Jaykay Wealth Advisors (JKWAI) offers asset management services through a wrap fee management program. In our wrap fee management program advisory services (including asset management) and transaction cost (including ticket charges) are provided for one fee. Whenever a fee is charged for services described in this Wrap Fee Program Brochure, we will receive all or a portion of the fee charged. When making the determination of whether one of the advisory programs available through JKWAI Advisors is appropriate for your needs, you should bear in mind that fee-based accounts, when compared with commission-based accounts, often result in lower costs during periods when trading activity is heavier, such as the year an account is established. However, during periods when trading activity is lower, the fee-based account arrangements may result in a higher annual cost for transactions. Thus, depending on a number of factors, the total cost for transactions under a fee account versus a commission account can vary significantly. Factors which affect the total cost include account size, amount of turnover, type and quantities of securities purchased or sold, commission rates and your tax situation. It should also be noted that lower fees for comparable service may be available from other sources. The exact fees and other terms will be outlined in the agreement between you and JKWAI. You should discuss the advantages and disadvantages of fee-based and commission-based accounts with your adviser representative and you should read this Wrap Fee Disclosure Brochure carefully as it explains, in detail, our Asset Management Services. Asset Management Services JKWAI offers asset management services, which involves JKWAI providing you with continuous and ongoing supervision over your accounts. The JKWAI Asset Management Services Program is a wrap fee program. In providing asset management services, JKWAI will continuously monitor your account and make trades in your accounts when necessary. Your account will be managed by JKWAI based on your financial situation, investment objectives and risk tolerance. JKWAI will actively monitor your account and will make management recommendations and decisions regarding buying, selling, reinvesting or holding securities, cash or other investments. We recommend that your assets to be allocated to our Asset Management Services Program be maintained in a brokerage account with LPL Financial and/or Schwab Institutional and/or SEI Jaykay Wealth Advisors, Inc Page 4 Form ADV Part 2A Appendix 1  Private Trust Company, SEC registered broker/dealers and members NYSE/SIPC. LPL Financial, Schwab, and SEI Private Trust Company are the qualified custodians for all accounts established through our Asset Management Services Program. You will appoint JKWAI as your investment adviser of record on specified accounts. Your account will consist only of separate account(s) held by the qualified custodian under your name. JKWAI does not act as custodian and does not have direct access to your funds and securities except to have advisory fees deducted from your account with your prior written authorization. The qualified custodian will maintain physical custody of all funds and securities of your Account, and you will retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) for your account. JKWAI provides discretionary investment advisory services to clients. The Investment Advisory Contract established with each client outlines the discretionary authority for trading. Where investment discretion has been granted, JKWAI generally manages the client’s account and makes investment decisions without consultation with the client as to what securities to buy or sell, when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, or the price per share. In some instances, JKWAI’s discretionary authority in making these determinations may be limited by conditions imposed by a client (in investment guidelines or objectives, or client instructions otherwise provided to JKWAI. Fees charged for our asset management services are charged based on a percentage of assets under management, managed accounts held and LPL and Schwab are billed in advance (at the start of the billing period) on a quarterly calendar basis and calculated based on the fair market value of your account as of the last business day of the previous billing period. SEI Account are billed quarterly in arrears. Fees are prorated (based on the number of days service is provided during the initial billing period) for your account opened at any time other than the beginning of the billing period. If asset management services are commenced in the middle of a billing period, the prorated fee for the initial billing period is billed in arrears at the same time as the next full billing period’s fee is billed. Advisory clients who have accounts at LPL Financial pay an Account Fee based on the value of the assets in the account as of the close of business on the last business day of the preceding quarter. The account fee is payable quarterly in advance – per the fee cycle established when the account is opened. For accounts under the Strategic Wealth Management Program “SWM”, the initial Account Fee is due at the beginning of the quarter following account inception and will be the prorated fee for the initial quarter in addition to the standard quarterly fee for the upcoming quarter. Jaykay Wealth Advisors, Inc Page 5 Form ADV Part 2A Appendix 1  For accounts under the Managed Account Solutions Program “MAS”, the initial account fee is due on the account inception date and will be prorated from the date of inception through the remaining current cycle 3 quarter (March/June/September/December). In regards to the standard quarterly fee, Advance billing is done on a quarterly basis and is the primary way Account Fees are assessed to advisory accounts. It is calculated as follows - [Quarter End Value X Advisory Account Fee] / 360 X 90 For all accounts, additional deposits and withdrawals will be added or subtracted from portfolio assets on a prorated basis to adjust the account fee. Quarterly billing adjustments account for any deposits or withdrawals made during the quarter. This is to ensure that the client is being charged only for the time the assets have resided in the account. To calculate the billing adjustments, the number of days each deposit and withdrawal was in the account must be determined. It is calculated in the following way – [Deposit or Withdrawal X Advisory Account Fee] / 360 X Prorated Dates = Billing Adjustment Fees charged for our asset management services are negotiable based on the type of client, the complexity of the client's situation, the composition of the client's account (i.e., equities versus mutual funds), the relationship of the client with the investment adviser representative, and the total amount of assets under management for the client. The final fee to be charged to the client account will be included in Exhibit I of the Investment Management Agreement. For our asset management services, client will be charged the following annual fee based upon the amount of assets under management: Total Assets Under Advisement Annual Fee Up to $500,000 1.50% $500,001 to $1,000,000 1.20% $1,000,001 to $3,000,000 1.00% $3,000,001 to $5,000,000 0.80% $5,000,001 to $7,000,000 0.70% $7,000,001 to $10,000,000 0.60% $10,000,001 to $15,000,000 0.55% $15,000,001 to $20,000,000 0.50% $20,000,001 to $25,000,000 0.45% Jaykay Wealth Advisors, Inc Page 6 Form ADV Part 2A Appendix 1  Total Assets Under Advisement Annual Fee $25,000,001 to $30,000,000 0.40% $30,000,001 and above 0.35% The only compensation received by JKWAI for asset management services is the annual fee as specified in the client’s advisory services agreement. JKWAI receives no other forms of compensation in connection with providing asset management services. JKWAI believes that its annual fee is reasonable in relation to: (1) services provided and (2) the fees charged by other investment advisers offering similar services/programs. However, our annual investment advisory fee may be higher than that charged by other investment advisers offering similar services/programs. In addition to our compensation, you may also incur charges imposed at the mutual fund level (e.g., advisory fees and other fund expenses). Clients can choose how to pay their investment advisory fees. The investment advisory fees can be deducted from their account and paid directly to our firm by the qualified custodian(s) of their account or clients will have the option to pay our firm or the qualified custodian upon receipt of a billing notice sent directly to you. If you choose to have the investment advisory fees deducted from your account, you must authorize the qualified custodian(s) of your account to deduct fees from your account and pay such fees directly to JKWAI. You should review your account statements received from the qualified custodian(s) and verify that appropriate investment advisory fees are being deducted. The qualified custodian(s) will not verify the accuracy of the investment advisory fees deducted. If you choose to have the investment advisory fees deducted from your account, you must authorize the qualified custodian(s) of your account to deduct fees from your account and pay such fees directly to JKWAI. You may incur certain charges imposed by third parties other than JKWAI in connection with investments made through your account including, but not limited to, mutual fund sales loads, 12(b)-1 fees and surrender charges, variable annuity fees and surrender charges, IRA and qualified retirement plan fees, and charges imposed by the qualified custodian(s) of your account. Management fees charged by JKWAI are separate and distinct from the fees and expenses charged by investment company securities that may be recommended to you. A description of these fees and expenses are available in each investment company security’s prospectus. Jaykay Wealth Advisors, Inc Page 7 Form ADV Part 2A Appendix 1  The asset management services continue until terminated by either party (i.e., JKWAI or you) by giving thirty (30) days written notice to the other party. Any prepaid, unearned fees will be promptly refunded by JKWAI to you. Fee refunds will be determined on a pro rata basis using the number of days services are provided during the final period. Block Trading JKWAI may elect to purchase or sell the same securities for several clients at approximately the same time. This process is referred to as aggregating orders, batch trading or block trading and is used by JKWAI when it is believed such action may prove advantageous to clients. If and when we aggregate client orders, allocating securities among client accounts is done on a fair and equitable basis. Typically, the process of aggregating client orders is done in order to achieve better execution, to negotiate more favorable commission rates or to allocate orders among clients on a more equitable basis in order to avoid differences in prices and transaction fees or other transaction costs that might be obtained when orders are placed independently. JKWAI uses the average price allocation method for transaction allocation. Under this procedure JKWAI will calculate the average price and transaction charges for each transaction included in a block order and assign the average price and transaction charge to each allocated transaction executed for the client’s account. If and when we determine to aggregate client orders for the purchase or sale of securities, including securities in which JKWAI or our associated persons may invest, we will do so in accordance with the parameters set forth in the SEC No-Action Letter, SMC Capital, Inc. Neither JKWAI nor our associated persons receive any additional compensation as a result of block trades. Suitability and Investment Strategy JKWAI will assist clients in determining their objective(s), investment strategy, and investment suitability, prior and subsequent to opening an Asset Management account. Clients must contact us to notify of any changes in their investment objective(s) and/or financial situation. Investment strategies used to implement investment advice include, but are not necessarily limited to, long term purchases (investments held at least a year). Additional Compensation, Economic and Non-Economic Benefits Our representatives are also registered representatives of LPL Financial, a securities broker- dealer. You may work with your investment adviser representative in his or her separate capacity as a registered representative of LPL Financial. When acting in his or her separate capacity as a registered representative, your investment adviser representative may sell, for commissions, general securities products such as stocks, bonds, mutual funds, exchange-traded Jaykay Wealth Advisors, Inc Page 8 Form ADV Part 2A Appendix 1  funds, and variable annuity and variable life products to you. As such, your investment adviser representative may suggest that you implement investment advice by purchasing securities products through a commission-based brokerage account in addition to or in lieu of a fee-based investment-advisory account. This receipt of commissions creates an incentive to recommend those products for which your investment adviser representative will receive a commission in his or her separate capacity as a registered representative of a securities broker-dealer. Consequently, the objectivity of the advice rendered to you could be biased. You are under no obligation to use the services of our representatives in this separate capacity or to use LPL Financial and can select any broker/dealer you wish to implement securities transactions. If you select our representatives to implement securities transactions in their separate capacity as registered representatives, they must use LPL Financial. Prior to effecting any such transactions, you are required to enter into a new account agreement with LPL Financial. The commissions charged by LPL Financial may be higher or lower than those charged by other broker/dealers. In addition, the registered representatives may also receive additional ongoing 12b-1 fees for mutual fund purchases from the mutual fund company during the period that you maintain the mutual fund investment. Effective October 7, 2019, Schwab has eliminated commissions for online trades of U.S. equities, ETFs and options (subject to $0.65 per contract fee). We encourage you to review Schwab’s pricing to compare the total costs of entering into a wrap fee arrangement versus a non-wrap arrangement. You will still incur commissions and fees for certain types of transactions in a non-wrap fee arrangement. To see what you would pay for transactions in a non-wrap account please refer to Schwab’s most recent pricing schedules available at www.schwab.com/aspricingguide. Other Custodian Economic Benefits: JKWAI receives an economic benefit from Schwab and/or SEI in the form of the support products and services it makes available to me and other independent investment advisers whose clients maintain their accounts at these custodians. These products and services, how they benefit us, and the related conflicts of interest are described above (see Item 12 – Brokerage Practices). The availability of the custodians’ products and services is not based on me giving particular investment advice, such as buying particular securities for my clients. We may from time to time receive expense reimbursement for travel and/or marketing expenses from distributors of investment and/or insurance products. Travel expense reimbursements are typically a result of attendance at due diligence and/or investment training events hosted by product sponsors. Marketing expense reimbursements are typically the result of informal expense sharing arrangements in which product sponsors may underwrite costs incurred for marketing such as client appreciation events, advertising, publishing, and seminar Jaykay Wealth Advisors, Inc Page 9 Form ADV Part 2A Appendix 1  expenses. Although receipt of these travel and marketing expense reimbursements are not predicated upon specific sales quotas, the product sponsor reimbursements are typically made by those sponsors for whom sales have been made or it is anticipated sales will be made. This creates a conflict of interest in that there is an incentive to recommend certain products and investments based on the receipt of this compensation instead of what is in the best interest of our clients. We attempt to control for this conflict by always basing investment decisions on the individual needs of our clients. Item 5 – Account Requirements and Types of Clients Minimum Account Size The minimum account size required to establish an account with JKWAI is $ 1,000,000. To reach this minimum, clients can aggregate all household accounts. However, JKWAI may waive this requirement under certain circumstances. All clients are required to execute an agreement for services in order to establish a client arrangement with JKWAI and/or the third-party money manager or the sponsor of third-party money manager platforms. Types of Accounts JKWAI generally provides investment advice to the following types of clients: Individuals • • High net worth individuals • Trusts, estates, or charitable organizations You are required to execute a written agreement with JKWAI specifying the particular advisory services in order to establish a client arrangement with JKWAI. Item 6 – Portfolio Manager Selection and Evaluation JKWAI and its Investment Adviser Representatives act as the portfolio manager(s) for accounts receiving our Asset Management Services. Our Asset Management Service is considered a wrap fee program. For this service, we do not allow the use of portfolio managers that are not associated with JKWAI. In other words, the only portfolio managers selected for managing client assets for our Asset Management Services are Investment Adviser Representatives of JKWAI. Therefore, conflicts of interest present in other wrap fee programs that make available both affiliated and unaffiliated portfolio managers are not present in our wrap fee program. Participation in Wrap Fee Programs Jaykay Wealth Advisors, Inc Page 10 Form ADV Part 2A Appendix 1  JKWAI offers asset management services, through our Asset Management Services Program, which is a wrap fee management program. Under this program we bundled all transaction fees in to a “wrap fee” meaning that advisory services (including portfolio management or advice regarding selecting other investment advisers) and transaction services are provided for one fee. Whenever a fee is charged to a client for services described in this Wrap Fee Program Brochure, we will receive all of a portion of the fee charged. General Description of Other Advisory Services The following are descriptions of the primary advisory services of JKWAI. Please understand that a written agreement, which details the exact terms of the service, must be signed by you and JKWAI before we can provide you the services described below. Financial Planning and Consulting Services – JKWAI offers financial planning services, which involve preparing a written financial plan covering specific or multiple topics. Depending upon the needs of the client we may provide financial plans, which typically address the following topics: Investment Planning, Retirement Planning, Insurance Planning, Tax Planning, and Education Planning. When providing financial planning services, the role of your investment adviser representative is to find ways to help you understand your overall financial situation and help you set financial objectives. We also provide modular written financial plans which only cover those specific areas of concern mutually agreed upon by you and us. A modular written financial plan is limited or segmented and does not involve the creation of a full written financial plan. You should be aware that there are important issues that may not be taken into consideration when your investment adviser representative develops his or her analysis and recommendations under a modular written financial plan. Written financial plans prepared by us under this Agreement do not include specific recommendations of individual securities. We also offer consultations in order to discuss financial planning issues when you do not need a written financial plan. We offer a one-time consultation, which covers mutually agreed upon areas of concern related to investments or financial planning. We also offer “as-needed” consultations, which are limited to consultations in response to a particular investment or financial planning issue raised or request made by you. Under an “as-needed” consultation, it will be incumbent upon you to identify those particular issues for which you are seeking our advice or consultation on. Our financial planning and consulting services do not involve implementing any transaction on your behalf or the active and ongoing monitoring or management of your investments or accounts. You have the sole responsibility for determining whether to implement our financial planning and consulting recommendations. To the extent that you would like to implement Jaykay Wealth Advisors, Inc Page 11 Form ADV Part 2A Appendix 1  any of our investment recommendations through JKWAI or retain JKWAI to actively monitor and manage your investments, you must execute a separate written agreement with JKWAI for our asset management services. Referral of Third-Party Money Managers - JKWAI offers advisory services by referring clients to a third-party money manager offering asset management and other investment advisory services. The third-party managers are responsible for continuously monitoring client accounts and making trades in client accounts when necessary. Under this program, we assist you with identifying your risk tolerance and investment objectives. We recommend third-party money managers in relation to your stated investment objectives and risk tolerance, and you may select a recommended third-party money manager or model portfolio based upon your needs. You must enter into an agreement directly with the third-party money manager who provides your designated account with asset management services. We are available to answer questions that you may have regarding your account and act as the communication conduit between you and the third-party money manager. The third-party money manager may take discretionary authority to determine the securities to be purchased and sold for your Account. We do not have any trading authority with respect to your designated account managed by the third-party money manager. Clients are advised that there may be other third-party managed programs not recommended by our firm, that are suitable for the client and that may be more or less costly than arrangements recommended by our firm. No guarantees can be made that a client’s financial goals or objectives will be achieved by a third-party investment adviser recommended by our firm. Further, no guarantees of performance can ever be offered by our firm. Retirement Plan Services - JKWAI offers retirement plan services to retirement plan sponsors and to individual participants in retirement plans. For a corporate sponsor of a retirement plan, our retirement plan services can include, but are not limited to, the following services: Fiduciary Consulting Services JKWAI provides the following Fiduciary Retirement Plan Consulting Services: • Non-Discretionary Investment Advice. JKWAI will provide you with general, non- discretionary investment advice regarding assets classes and investment options, consistent with your Plan’s investment policy statement. Jaykay Wealth Advisors, Inc Page 12 Form ADV Part 2A Appendix 1  • • • Investment Selection Services. JKWAI will provide you with recommendations of investment options consistent with ERISA section 404(c). Investment Due Diligence Review. JKWAI will provide you with periodic due diligence reviews of the Plan’s reports, investment options and recommendations. Investment Monitoring. JKWAI will assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformation to the guidelines set forth in the investment policy statement and JKWAI will make recommendations to maintain or remove and replace investment options. • • Default Investment Alternative Advice. JKWAI will provide you with non-discretionary investment advice to assist you with the development of qualified default investment alternative(s) (“QDIA”), as defined in DOL Reg. Section 2550.404c-5(e)(4)(i), for participants who are automatically enrolled in the Plan or who otherwise fail to make an investment election. You will retain the sole responsibility to provide all notices to participants required under ERISA section 404(c)(5). Individualized Participant Advice. Upon request, JKWAI will provide one-on-one advice to Plan participants regarding their individual situations. For Fiduciary Consulting Services, all recommendations of investment options and portfolios will be submitted to you for your ultimate approval or rejection. For retirement plan Fiduciary Consulting Services, the retirement plan sponsor client or the plan participant who elects to implement any recommendations made by us is solely responsible for implementing all transactions. Fiduciary Consulting Services are not management services, and JKWAI does not serve as administrator or trustee of the plan. JKWAI does not act as custodian for any client account or have access to client funds or securities (with the exception of, some accounts, having written authorization from the client to deduct our fees). JKWAI acknowledges that in performing the Fiduciary Consulting Services listed above that it is acting as a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of Employee Retirement Income Security Act of 1974 (“ERISA”) for purposes of providing non-discretionary investment advice only. JKWAI will act in a manner consistent with the requirements of a fiduciary under ERISA if, based upon the facts and circumstances, such services cause JKWAI to be a fiduciary as a matter of law. However, in providing the Fiduciary Consulting Services, JKWAI (a) has no responsibility and will not (i) exercise any discretionary authority or discretionary control respecting management of Client’s retirement plan, (ii) exercise any authority or control respecting management or disposition of assets of Client’s retirement plan, or (iii) have any discretionary authority or discretionary responsibility in the administration of Client’s retirement plan or the interpretation of Client’s retirement plan documents, (b) is not an Jaykay Wealth Advisors, Inc Page 13 Form ADV Part 2A Appendix 1  “investment manager” as defined in Section 3(38) of ERISA and does not have the power to manage, acquire or dispose of any plan assets, and (c) is not the “Administrator” of Client’s retirement plan as defined in ERISA. Non-Fiduciary Services Although an investment adviser is considered a fiduciary under the Investment Advisers Act of 1940 and required to meet the fiduciary duties as defined by the Advisers Act, the services listed here as non-fiduciary should not be considered fiduciary services for the purposes of ERISA since Advisor is not acting as a fiduciary to the Plan as the term “fiduciary” is defined in Section 3(21)(A)(ii) of ERISA. The exact suite of services provided to a client will be listed and detailed in the Qualified Retirement Plan Agreement. JKWAI provides clients with the following Non-Fiduciary Retirement Plan Consulting Services: • Participant Education. JKWAI will provide education services to Plan participants about general investment principles and the investment alternatives available under the Plan. JKWAI’s assistance in participant investment education will be consistent with and within the scope of DOL Interpretive Bulletin 96-1. Education presentations will not take into account the individual circumstances of each participant and individual recommendations will not be provided unless otherwise agreed upon. Plan participants are responsible for implementing transactions in their own accounts. • Participant Enrollment. JKWAI will assist you with group enrollment meetings designed to increase retirement plan participation among employees and investment and financial understanding by the employees. • Qualified Plan Development. JKWAI will assist you with the establishment of a qualified plan by working with you and a selected Third Party Administrator. If you have not already selected a Third Party Administrator, we shall assist you with the review and selection of a Third Party Administrator for the Plan. • Due Diligence Review. JKWAI will provide you with periodic due diligence reviews of your Plan’s fees and expenses and your Plan’s service providers. • Benchmarking. JKWAI will provide you benchmarking services and will provide analysis concerning the operations of the Plan. Securities and other types of investments all bear different types and levels of risk. Those risks are typically discussed with clients in defining the investment policies and objectives that will guide investment decisions for their qualified plan accounts. Upon request, as part of our retirement plan services, we can discuss those investments and investment strategies that we Jaykay Wealth Advisors, Inc Page 14 Form ADV Part 2A Appendix 1  believe may tend to reduce these risks for a particular client’s circumstances and plan participants. Clients and plan participants must realize that obtaining higher rates of return on investments entails accepting higher levels of risk. Based upon discussions with the client, we will attempt to identify the balance of risks and rewards that is appropriate and comfortable for the client and other employees. It is still the clients’ responsibility to ask questions if the client does not fully understand the risks associated with any investment. All plan participants are strongly encouraged to read prospectuses, when applicable, and ask questions prior to investing. We strive to render our best judgment for clients. Still, JKWAI cannot assure that investments will be profitable or assure that no losses will occur in their portfolios. Past performance is an important consideration with respect to any investment or investment advisor, but it is not necessarily an accurate predictor of future performance. JKWAI will disclose, to the extent required by ERISA Regulation Section 2550.408b-2(c), to you any change to the information that we are required to disclose under ERISA Regulation Section 2550.408b-2(c)(1)(iv) as soon as practicable, but no later than sixty (60) days from the date on which we are informed of the change (unless such disclosure is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclosed as soon as practicable). In accordance with ERISA Regulation Section 2550.408b-2(c)(vi)(A), we will disclose within thirty (30) days following receipt of a written request from the responsible plan fiduciary or Plan Administrator (unless such disclose is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclosed as soon as practicable) all information related to the Qualified Retirement Plan Agreement and any compensation or fees received in connection with the Agreement that is required for the Plan to comply with the reporting and disclosure requirements of Title 1 of ERISA and the regulations, forms and schedules issued thereunder. If we make an unintentional error or omission in disclosing the information required under ERISA Regulation Section 2550.408b-2(c)(1)(iv) or (vi), we will disclose to you the correct information as soon as practicable, but no later than thirty (30) days from the date on which we learn of such error or omission. Educational Seminars/Workshops Jaykay Wealth Advisors, Inc Page 15 Form ADV Part 2A Appendix 1  JKWAI occasionally provides seminars/workshops in areas such as financial planning, retirement planning, estate planning, college planning and charitable planning or other relevant financial topics. Seminars/ workshops are always offered on an impersonal basis and do not focus on the individual needs of participants. Limits Advice to Certain Types of Investments JKWAI provides investment advice on the following types of investments: • Mutual Funds • Exchange-listed Securities • REITS, Insurance and Annuities • Hedge Funds • Business Development Companies Although we generally provide advice only on the products previously listed, we reserve the right to offer advice on any investment product that may be suitable for each client’s specific circumstances, needs, goals and objectives. It is not our typical investment strategy to attempt to time the market, but we may increase cash holdings modestly as deemed appropriate based on your risk tolerance and our expectations of market behavior. We may modify our investment strategy to accommodate special situations such as low basis stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations. Tailor Advisory Services to Individual Needs of Clients JKWAI’s advisory services are always provided based on your individual needs. This means, for example, that when we provide asset management services, you are given the ability to impose restrictions on the accounts we manage for you, including specific investment selections and sectors. We work with you on a one-on-one basis through interviews and questionnaires to determine your investment objectives and suitability information. We will not enter into an investment adviser relationship with a prospective client whose investment objectives may be considered incompatible with our investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. Performance-Based Fees and Side-By-Side Management Jaykay Wealth Advisors, Inc Page 16 Form ADV Part 2A Appendix 1  Performance-based fees are defined as fees based on a share of capital gains on or capital appreciation of the assets held in a client’s account. JKWAI does not charge or accept performance-based fees. Methods of Analysis JKWAI uses the following methods of analysis in formulating investment advice: Modern portfolio theory is a theory of investment which attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, by carefully choosing the proportions of various assets. There are risks involved in using any analysis method. Investment Strategies JKWAI uses the following investment strategies when managing client assets and/or providing investment advice: Long term purchases, investments held at least a year. Risk of Loss Past performance is not indicative of future results. Therefore, you should never assume that future performance of any specific investment or investment strategy will be profitable. Investing in securities (including stocks, mutual funds, and bonds, etc.) involves risk of loss. Further, depending on the different types of investments there may be varying degrees of risk. You should be prepared to bear investment loss including loss of original principal. Because of the inherent risk of loss associated with investing, our firm is unable to represent, guarantee, or even imply that our services and methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate you from losses due to market corrections or declines. There are certain additional risks associated with investing in securities through our investment management program, as described below: • Market Risk – Either the stock market as a whole, or the value of an individual company, goes down resulting in a decrease in the value of client investments. This is also referred to as systemic risk. • Equity (stock) market risk – Common stocks are susceptible to general stock market fluctuations and to volatile increases and decreases in value as market confidence in and perceptions of their issuers change. If you held common stock, Jaykay Wealth Advisors, Inc Page 17 Form ADV Part 2A Appendix 1  or common stock equivalents, of any given issuer, you would generally be exposed to greater risk than if you held preferred stocks and debt obligations of the issuer. • Company Risk. When investing in stock positions, there is always a certain level of company or industry specific risk that is inherent in each investment. This is also referred to as unsystematic risk and can be reduced through appropriate diversification. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. For example, if a company’s employees go on strike or the company receives unfavorable media attention for its actions, the value of the company may be reduced. • Fixed Income Risk. When investing in bonds, there is the risk that the issuer will default on the bond and be unable to make payments. Further, individuals who depend on set amounts of periodically paid income face the risk that inflation will erode their spending power. Fixed-income investors receive set, regular payments that face the same inflation risk. • ETF and Mutual Fund Risk – When investing in an ETF or mutual fund, you will bear additional expenses based on your pro rata share of the ETF’s or mutual fund’s operating expenses, including the potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities the ETF or mutual fund holds. You will also incur brokerage costs when purchasing ETFs. • Management Risk – Your investment with our firm varies with the success and failure of our investment strategies, research, analysis and determination of portfolio securities. If our investment strategies do not produce the expected returns, the value of the investment will decrease. Voting Client Securities JKWAI does not vote proxies on behalf of Clients. We have determined that taking on the responsibilities for voting client securities does not add enough value to the services provided to you to justify the additional compliance and regulatory costs associated with voting client securities. Therefore, it is your responsibility to vote all proxies for securities held in Account. You will receive proxies directly from the qualified custodian or transfer agent; we will not provide you with the proxies. You are encouraged to read through the information provided with the proxy-voting documents and make a determination based on the information provided. Jaykay Wealth Advisors, Inc Page 18 Form ADV Part 2A Appendix 1  With respect to assets managed by a third-party money manager, we will not vote the proxies associated with these assets. You will need to refer to each third-party money manager’s disclosure brochure to determine whether the third-party money manager will vote proxies on your behalf. You may request a complete copy of third-party money manager’s proxy voting policies and procedures as well as information on how your proxies were voted by contacting the third-party money manager or by contacting JKWAI at the address or phone number indicated on Page 1 of this disclosure document. Item 7 – Client Information Provided to Portfolio Managers Only Investment Adviser Representatives of JKWAI serve as portfolio managers for our Asset Management Services Program. Our associated Investment Adviser Representatives are responsible for gathering all information provided by you. We will interview and work with you to gather all information needed relative to your investment objectives and needs in order to provide management services through our Asset Management Services Program. You are responsible for promptly contacting your Investment Adviser Representative to notify us of any changes to your financial situation that will impact or materially influence the way we manage your accounts. Item 8 - Client Contact with Portfolio Managers Only Investment Adviser Representatives of JKWAI serve as portfolio managers for our Asset Management Services Program. There are no restrictions placed on your ability to contact and consult with their portfolio managers. It is the policy of JKWAI to provide for open communications between the Investment Adviser Representatives and clients. You are encouraged to contact your Investment Adviser Representative whenever you have questions about the management of your account(s). Item 9 - Additional Information Disciplinary Information We have no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of our business or the integrity of our management. Other Financial Industry Activities and Affiliations JKWAI is not and does not have a related person that is a broker/dealer, municipal securities dealer, government securities dealer or broker, an investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), another investment Jaykay Wealth Advisors, Inc Page 19 Form ADV Part 2A Appendix 1  adviser or financial planner, a futures commission merchant, commodity pool operator, or commodity trading advisor, a banking or thrift institution, an accountant or accounting firm, a lawyer or law firm, an insurance company or agency, a pension consultant, a real estate broker or dealer, and a sponsor or syndicator of limited partnerships. We are an independent registered investment adviser and only provide investment advisory services. We are not engaged in any other business activities and offer no other services except those described in this Disclosure Brochure. However, while we do not sell products or services other than investment advice, our representatives may sell other products or provide services outside of their role as investment adviser representatives with JKWAI. Registered Representative of a Broker-Dealer Our representatives are also registered representatives of LPL Financial, a securities broker- dealer. You may work with your investment adviser representative in his or her separate capacity as a registered representative of LPL Financial. When acting in his or her separate capacity as a registered representative, your investment adviser representative may sell, for commissions, general securities products such as stocks, bonds, mutual funds, exchange-traded funds, and variable annuity and variable life products to you. As such, your investment adviser representative may suggest that you implement investment advice by purchasing securities products through a commission-based brokerage account in addition to or in lieu of a fee-based investment-advisory account. This receipt of commissions creates an incentive to recommend those products for which your investment adviser representative will receive a commission in his or her separate capacity as a registered representative of a securities broker-dealer. Consequently, the objectivity of the advice rendered to you could be biased. You are under no obligation to use the services of our representatives in this separate capacity or to use LPL Financial and can select any broker/dealer you wish to implement securities transactions. If you select our representatives to implement securities transactions in their separate capacity as registered representatives, they must use LPL Financial. Prior to effecting any such transactions, you are required to enter into a new account agreement with LPL Financial. The commissions charged by LPL Financial may be higher or lower than those charged by other broker/dealers. In addition, the registered representatives may also receive additional ongoing 12b-1 fees for mutual fund purchases from the mutual fund company during the period that you maintain the mutual fund investment. SEI Asset Management Program The SEI Asset Management Program (SEI Program) is an institutional asset allocation program that JKWAI uses in the management of assets for client accounts. If you enroll in the SEI Asset Management Program, JKWAI will assist you in the establishment of a SEI Program Account Jaykay Wealth Advisors, Inc Page 20 Form ADV Part 2A Appendix 1  (the Account) at SEI Private Trust Company (SEI). All Account transactions are processed and cleared through SEI. The SEI Program uses asset allocation portfolios developed by SEI Investments. The portfolios consist of SEI Family of Institutional Mutual Funds (Mutual Funds) and other securities approved by SEI to be held in an account. The SEI Program uses the Portfolio Managers selected and subject to oversight by SEI and who have entered into a sub- advisory agreement with SEI. JKWAI will provide SEI with the asset allocation policy that you select for your account. JKWAI will direct SEI to reallocate your investments in accordance with your Asset Allocation Policy. In addition, based on JKWAI instructions, SEI will rebalance the investments within your account at least annually so that the market value of the shares of each mutual fund held in your account is the same percentage of the total market value of your account as required by your Asset Allocation Policy. SEI and its Portfolio Managers will have discretionary authority over the assets and transactions in the Account. JKWAI will have discretionary authority to re- allocate your portfolios among the various Portfolio Managers as needed. SEI has the authority to replace a previously selected Portfolio Manager or SEI Fund without your prior approval. Custody of all SEI Program Client Account assets is held at SEI Private Trust Company. Insurance Agent You may work with your investment adviser representative in his or her separate capacity as an insurance agent. When acting in his or her separate capacity as an insurance agent, the investment adviser representative may sell, for commissions, general disability insurance, life insurance, annuities, and other insurance products to you. As such, your investment adviser representative in his or her separate capacity as an insurance agent, may suggest that you implement recommendations of JKWAI by purchasing disability insurance, life insurance, annuities, or other insurance products. This receipt of commissions creates an incentive for the representative to recommend those products for which your investment adviser representative will receive a commission in his or her separate capacity as an insurance agent. Consequently, the advice rendered to you could be biased. You are under no obligation to implement any insurance or annuity transaction through your investment adviser representative. Interest in Client Transactions and Code of Ethics JKWAI has established a Code of Ethics that will apply to all of its associated persons. As a fiduciary, it is an investment advisor’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. JKWAI has a fiduciary duty to all clients. This fiduciary duty is considered the core underlying principle for our Code of Ethics which also covers our Insider Trading and Personal Securities Transactions Jaykay Wealth Advisors, Inc Page 21 Form ADV Part 2A Appendix 1  Policies and Procedures. JKWAI has the responsibility to make sure that the interests of all clients are placed ahead of JKWAI’s own investment interest. Full disclosure of all material facts and potential conflicts of interest will be provided to clients prior to any services being conducted. JKWAI will conduct business in an honest, ethical and fair manner and avoid all circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients. This section is intended to provide clients with a summary of JKWAI’s Code of Ethics. Clients may receive a complete copy of the Code of Ethics upon request. Affiliate and Employee Personal Securities Transactions Disclosure JKWAI or associated persons of the firm may buy or sell for their personal accounts, investment products identical to those recommended to clients. This creates a potential conflict of interest. It is the express policy of JKWAI that all persons associated in any manner with our firm must place clients’ interests ahead of their own when implementing personal investments. JKWAI and its associated persons will not buy or sell securities for their personal account(s) where their decision is derived, in whole or in part, by information obtained as a result of employment or association with our firm unless the information is also available to the investing public upon reasonable inquiry. We are now and will continue to be in compliance with applicable state and federal rules and regulations. To prevent conflicts of interest, we have developed written supervisory procedures that include personal investment and trading policies for our representatives, employees and their immediate family members (collectively, associated persons): • Associated persons cannot prefer their own interests to that of the client. • Associated persons cannot purchase or sell any security for their personal accounts prior to implementing transactions for client accounts. • Associated persons cannot buy or sell securities for their personal accounts when those decisions are based on information obtained as a result of their employment, unless that information is also available to the investing public upon reasonable inquiry. • Associated persons are prohibited from purchasing or selling securities of companies in which any client is deemed an “insider”. • Associated persons are discouraged from conducting frequent personal trading. • Associated persons are generally prohibited from serving as board members of publicly traded companies unless an exception has been granted to the Chief Compliance Officer of JKWAI. Any associated person not observing our policies is subject to sanctions up to and including termination. Jaykay Wealth Advisors, Inc Page 22 Form ADV Part 2A Appendix 1  Account Reviews Managed accounts are reviewed at least annually. While the calendar is the main triggering factor, reviews can also be conducted at your request. Account reviews will include investment strategy and objectives review and making a change if strategy and objectives have changed. Reviews are conducted by your assigned Investment Advisor Representative, with reviews performed in accordance with your investment goals and objectives. Accounts established and maintained with other third-party money managers are reviewed at least annually. Account Statements and Reports For our asset management services, you are provided with transaction confirmation notices and regular quarterly account statements directly from the qualified custodian. Additionally, JKWAI may provide position or performance reports to you quarterly and upon request. Whether reports by an outside money manager are provided to you will depend upon the outside money manager. You are encouraged to always compare any reports or statements provided by us, a sub-adviser or third-party money manager against the account statements delivered from the qualified custodian. When you have questions about your account statement, you should contact our firm and the qualified custodian preparing the statement. Client Referrals JKWAI does not directly or indirectly compensate any person for client referrals. The only compensation received from advisory services is the fees charged for providing investment advisory services. JKWAI receives no other forms of compensation in connection with providing investment advice. 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 advisers whose clients maintain their accounts at Schwab. These products and services, how they benefit us, and the related conflicts of interest are described above. The availability of Schwab’s products and services is not based on us giving particular investment advice, such as buying particular securities for our clients. Financial Information Jaykay Wealth Advisors, Inc Page 23 Form ADV Part 2A Appendix 1  JKWAI does not require or solicit prepayment of more than $1200 in fees per client, six months or more in advance. Therefore, we are not required to include a balance sheet for the 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 clients. Finally, JKWAI has not been the subject of a bankruptcy petition at any time. Jaykay Wealth Advisors, Inc Page 24 Form ADV Part 2A Appendix 1