JESSUP WEALTH MANAGEMENT

Form ADV Part 2A Item 1 – Cover Page Jessup Wealth Management 35 Park Avenue Dayton, OH 45419 (937) 938-9105 http://www.jessupwealthmanagement.com/ April 2026 This brochure provides information about the qualifications and business practices of Jessup Wealth Management. If you have any questions about the contents of this brochure, please contact us using the information above. 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. Jessup Wealth Management (CRD# 323035) is a registered investment adviser with the SEC. Registration as an investment adviser does not imply a certain level of skill or training. information about Jessup Wealth Management also is available on the SEC’s website at Additional www.adviserinfo.sec.gov. 1  Item 2 – Material Changes Since the firm’s brochure update on March 3, 2025, we have made the following changes: • We have added Charles Schwab & Co., Inc. (“Schwab”) as an additional qualified custodian to maintain custody of our clients’ assets and to effect trades for their accounts. Please refer to Items 12 and 14 for additional information. • We have updated our fee schedule disclosure to more accurately describe the methodology used to calculate advisory fees. Specifically, we revised the description from a blended (or “linear”) tiered fee structure, under which different fee rates apply to the portion of assets within each applicable tier, to a breakpoint (or “step-rate”) tiered fee structure, under which all the assets qualify for the lower fee rate. This change is intended to clarify our billing practices and does not reflect a change to how client fees are actually calculated. Under the breakpoint methodology, the effective rate may be lower than under a linear tier calculation, but in no case will the advisory fee be higher. Clients’ investment management fees as agreed to in their Investment Management Agreement remain unchanged. Please refer to Item 5 for additional information. You may request a copy of our current Brochure at any time, without charge, by contacting us at the phone number or email address on this cover page of this brochure. Additional information about Jessup Wealth Management is available via the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov. The SEC’s website also provides information about any persons affiliated with Jessup Wealth Management who are registered, or are required to be registered, as Investment Adviser Representatives of Jessup Wealth Management. 2  Item 3: Table of Contents Item 1 – Cover Page ............................................................................................................................................ 1 Item 2 – Material Changes .................................................................................................................................. 2 Item 4 – Advisory Business ................................................................................................................................. 4 Item 5 – Fees and Compensation ....................................................................................................................... 7 Item 6 – Performance-Based Fees and Side-By-Side Management ................................................................. 13 Item 7 – Types of Clients ................................................................................................................................... 13 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................................ 13 Item 9 – Disciplinary Information ..................................................................................................................... 20 Item 10 – Other Financial Industry Activities and Affiliations .......................................................................... 20 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................... 21 Item 12 – Brokerage Practices .......................................................................................................................... 21 Item 13 – Review of Accounts ........................................................................................................................... 26 Item 14 – Client Referrals and Other Compensation ........................................................................................ 26 Item 15 – Custody ............................................................................................................................................. 28 Item 16 – Investment Discretion ...................................................................................................................... 28 Item 17 – Voting Client Securities ..................................................................................................................... 29 Item 18 – Financial Information ........................................................................................................................ 29 3  Item 4 – Advisory Business Jessup Wealth Management is a registered investment adviser, offering financial planning and asset management services to clients. Jessup Wealth Management has been in business since 2009, and its principal owners are Mark McEvily and Matthew Jessup. This Brochure is designed to provide detailed and clear information relating to each item noted in the table of contents. Certain disclosures are repeated in one or more items, and/or other items are referred to in an effort to be as comprehensive as possible on the broad subject matters discussed. Within this Brochure, certain terms in either upper- or lowercase are used as follows: • • • “We,” “us,” “our” and “JWM” refer to Jessup Wealth Management. “Advisor” refers to persons who provide investment recommendations or advice on behalf of Jessup Wealth Management. “You,” “yours,” and “client” refer to clients of Jessup Wealth Management and its advisors. Description of Services Available Jessup Wealth Management offers a suite of investment advisory services and programs to its advisors for use with their clients. Our investment advisory services and programs are designed to accommodate a wide range of client investment philosophies, goals, needs, and investment objectives. Through these various advisory programs and services, clients have access to a wide range of securities products, including, but not limited to, common and preferred stocks; municipal, corporate, and government fixed income securities; mutual funds; exchange-traded products (“ETPs”); options and derivatives; unit investment trusts (“UITs”); and variable and fixed-indexed insurance products, as well as other products and services, including a variety of asset allocation services, financial planning, and consulting services. Our advisors may also offer advice related to direct participation programs, private placements, and other alternative investments, such as alternative energy programs, research and development programs, leasing programs, real estate programs, and pooled commodities futures programs. Jessup Wealth Management offers the following programs: Financial Planning Services Jessup Wealth Management’s advisors provide advisory consulting services on a wide range of topics, including, but not limited to, comprehensive financial planning, risk management and insurance planning, banking and credit management, budgeting and cash flow analysis, major purchases, education planning, retirement income/longevity planning, portfolio analysis, estate planning analysis (including planning for incapacity), charitable giving planning, executive compensation planning, debt extinguishment planning, investment analysis, business succession planning, and fringe benefit analysis. Our financial planning process begins with a consultation to determine your assets, liabilities, investment objectives, present and future foreseeable financial obligations, income, and risk tolerance. Using this information, we will create a financial plan consistent with your needs. When the plan is completed, we will meet with you to present the plan and answer any question you may have. You may also engage us for an annual update of your financial plan. The fees for both the initial plan and subsequent annual updates (if desired) are listed in Item 5 of this brochure. 4  Commonwealth Programs Jessup Wealth Management has entered into an agreement to offer clients access to certain programs offered by Commonwealth Financial Network (“Commonwealth”), an SEC-registered investment adviser investment advisory programs sponsored by Commonwealth. Specifically, to offer certain Commonwealth’s Retirement Plan Consulting Program, PPS Custom Account Program and PPS Select Account Program are available to our clients as appropriate for the client’s individual situation. Retirement Plan Consulting: We provide a fee-for-service consulting program whereby our advisors offer onetime or ongoing advisory services to qualified retirement plans. Qualified plan clients may engage our advisors for Retirement Plan Consulting services on a negotiated hourly, flat, fixed, or asset-based fee basis. The maximum annual consulting fee, when stated as a percentage of assets, is 1.50% and is negotiable. Hourly fees may not exceed $500 per hour. It is the responsibility of the plan sponsor to ensure these fees are reasonable. Fees may be paid at the time of service, in advance of service, or after service has been rendered. Through the Retirement Plan Consulting Program, advisors assist plan sponsors with their fiduciary duties and provide individualized advice based upon the needs of the plan and/or plan participants regarding investment management matters, such as: Investment policy statement support • • Plan menu design and monitoring • Service provider support • Participant advice programs Asset Management Services PPS Custom: The PPS Custom Program enables an advisor to assist the client in developing a personalized investment portfolio using one or more investment types, including, but not limited to, stocks, bonds, mutual funds, exchange-traded funds (“ETFs”), UITs, variable and fixed-indexed annuities, and alternative investments. The advisor typically acts as portfolio manager, with full investment discretion, although clients may elect to have the advisor manage the account on a nondiscretionary basis. PPS Select: The PPS Select Program offers a variety of model portfolios from which investors may choose. The PPS Select model portfolios are created and managed on a discretionary basis by Commonwealth’s Investment Management and Research team. The client’s advisor will help the client determine which PPS Select models are best suited for the client based on his or her risk profile, investment objectives, and preferences, leaving the actual trading decisions to Commonwealth’s Investment Management and Research team. PPS Select offers a variety of model portfolios with varying investment product types, including mutual fund and ETF portfolios, equity portfolios, fixed income portfolios, and variable annuity subaccount portfolios. Clients who participate in one or more of Commonwealth’s programs will receive Commonwealth’s Form ADV Part 2 and/or Wrap Fee Brochure, in addition to Jessup Wealth Management’s Form ADV Part 2. Clients should refer to Commonwealth’s Form ADV Part 2 and/or Wrap Fee Brochure for detailed information about Commonwealth and Commonwealth’s programs. Wrap Fee Programs The PPS Custom and PPS Select programs sponsored by Commonwealth and offered by Jessup Wealth Management are considered “wrap fee” programs in which the client pays a specified fee (known as a 5  “wrap fee”) for portfolio management services and trade execution. Wrap fee programs differ from non- wrap fee programs in that the asset management fee structure for wrap programs is intended to be largely all-inclusive, whereas non-wrap fee programs assess trade execution costs that are typically in addition to the asset management fee. For the investment advisory services provided to you by Jessup Wealth Management and your advisor, Commonwealth, Jessup Wealth Management and your advisor receive a portion of the wrap fees you pay. Commonwealth receives a higher portion of the wrap fees you pay when you participate in Commonwealth’s PPS Select programs to compensate for the investment management and research services provided by the Commonwealth Investment Management and Research team. For more information relating to Commonwealth’s wrap fee programs, please refer to Appendix 1 of Commonwealth’s Form ADV Part 2A brochure, titled “The Wrap Fee Program Brochure.” Program Choices The specific advisory program you select may cost you more or less than purchasing program services separately. Factors that bear upon the cost of a particular advisory program in relation to the cost of the same services purchased separately include, but may not be limited to, the type and size of the account; the historical or expected size or number of trades for the account; the types of securities and strategies involved; the amount of fees, commissions, and other charges that apply at the account or transaction level; and the number and range of supplementary advisory and client-related services provided to the account. Lower fees for comparable services may be available from other sources. Individualized Services and Client-Imposed Restrictions The investment advisory services provided by our advisors depend largely on the personal information the client provides to the advisor. In order for our advisors to provide appropriate investment advice to, or, in the case of discretionary accounts, make tailored investment decisions for, the client, it is very important that clients provide accurate and complete responses to their advisor’s questions about their financial condition, needs, goals, and objectives and notify the advisor of any reasonable restrictions they wish to apply to the securities or types of securities to be bought, sold, or held in their managed account. It is also important that clients promptly inform their advisor of any changes in their financial condition, investment objectives, personal circumstances, or reasonable investment restrictions pertaining to the management of their account, if any, that may affect their overall investment goals and strategies or the investment advice provided or investment decisions made by their advisor. Assets Under Management As of December 31, 2025, Jessup Wealth Management manages $360,187,043.80 in assets. All assets are managed on a discretionary basis. Program Choice Conflicts of Interest Clients should be aware that the compensation to Jessup Wealth Management and your advisor will differ according to the specific advisory programs or services provided. This compensation to Jessup Wealth Management and your advisor may be more than the amounts we would otherwise receive if you participated in another program or paid for investment advice, brokerage, or other relevant services separately. Lower fees for comparable services may be available through our firm or from other sources. Jessup Wealth Management and your advisor have a financial incentive to recommend advisory programs or services that provide us higher compensation over other comparable programs or services available from our firm or elsewhere that may cost you less. For example, the costs you will incur to have your account managed by our firm may be more than what other similar firms may charge. It’s important to 6  understand all the associated costs and benefits the program and services you select so you can decide which programs and services are best suited for your unique financial goals, investment objective, and time horizon. We encourage you to review our Form CRS and to discuss your options with your advisor. Factors that bear upon the cost of a particular advisory program in relation to the cost of the same services purchased separately include, but may not be limited to, the type and size of the account; the historical or expected size or number of trades for the account; the types of securities and strategies involved; the amount of fees and other charges that apply at the account or transaction level; and the number and range of supplementary advisory and client-related services provided to the account. Lower fees for comparable services may be available from other sources. You are under no obligation to engage us for services and are free to use the firm of your choice. In addition, Commonwealth offers our firm and our advisors one or more forms of financial benefits based on our total assets in Commonwealth’s PPS Program accounts, as well as financial assistance for transitioning from another firm to Commonwealth. The types of financial benefits that your advisor may receive from Commonwealth include, but are not limited to, forgivable or unforgivable loans, enhanced payouts, and discounts or waivers on transaction, platform, and account fees; technology fees; research package fees; financial planning software fees; administrative fees; brokerage account fees; account transfer fees; licensing and insurance costs; and the cost of attending conferences and events. The enhanced payouts, discounts, and other forms of financial benefits that your advisor may have the opportunity to receive from Commonwealth provide a financial incentive for our firm and your advisor to select Commonwealth as broker/dealer for your accounts over other broker/dealers from which they may not receive similar financial benefits. Please see items 12 and 14 of this Brochure for more detailed information about these types of conflicts and our relationship with Commonwealth. Commonwealth charges our advisors an administrative fee at the same time clients are charged asset- based fees for their managed accounts. The administrative fee is charged to and paid by the advisor rather than the advisor’s clients and is calculated as a percentage of the total managed account assets, including cash and money market positions, held by the advisor’s clients. The administrative fee is used to offset Commonwealth’s maintenance costs associated with account reporting and reconciliation. In the same manner as many advisors offer asset management fee discounts to their larger clients, Commonwealth offers those advisors to whom it charges administrative fees discounts based on their total assets under management. As these advisors grow their business, they are eligible for reduced administrative fees. This potential reductions in administrative fees presents a conflict of interest because it provides a financial incentive for advisors who receive the discounts to recommend Commonwealth’s PPS programs over other available programs that do not offer such potential discounts to the advisors. Item 5 – Fees and Compensation Asset Management Programs Clients who elect to receive asset management services through one or more of Jessup Wealth Management’s asset management programs will generally pay Jessup Wealth Management and their advisor for those services with an annual asset management fee based on a percentage of assets under management, including cash and money market positions. The maximum advisory fee that can be charged in any of our firm’s managed account program is listed in the fee schedule below. For accounts in custody at Schwab or a custodian other than NFS, JWM assesses an annual platform (aka infrastructure or administrative) fee designed to help offset the administrative costs associated with managing client assets, including trade execution and reporting. This annual platform fee for non-NFS accounts ranges 7  from .01% to .05% and is calculated based on the client’s total assets using a blended tier schedule as outlined in the client’s advisory agreement. Certain managed account programs have lower maximum annual fee amounts, and fee schedules will vary among programs. Clients are urged to carefully review and discuss the contents of this Brochure with their advisor, including descriptions of the various programs and services offered, the fees and charges clients will pay, the means by which Jessup Wealth Management and your advisor are compensated, and the conflicts of interest that exist between the client and Jessup Wealth Management and your advisor in respect to each program or service offered, to determine the most appropriate programs or services for your specific needs. JWM uses a breakpoint management fee schedule, meaning the entire account is charged the same advisory fee. Investment management fees for Commonwealth program accounts are billed quarterly in advance based on the amount of assets managed at the close of business on the last business day of the previous billing period. Investment advisory fees for accounts managed by JWM at Schwab are billed monthly in arrears based on the average daily account balance. Lastly, please note that JWM may group certain related Client accounts, often known as “householding”, for the purposes of achieving the minimum annualized fee. Assets Under Management Annual Fee Less than $1,000,000 2.00% $100,000,000 - $2,000,000 1.75% $2,000,000 - $3,000,000 1.50% $3,000,000 - $5,000,000 1.25% $5,000,000 - $7,500,000 1.00% $7,500,000 - $15,000,000 .85% $15,000,000 + .75% All JWM advisory program fees are negotiable. Clients may also be billed on a fixed fee basis rather than using one of the firm’s standard fee schedules as may be agreed to by the firm and the client. Platform fees (if applicable), transaction charges and other account-related fees assessed by Commonwealth, JWM, or Schwab are not negotiable. JWM may waive all or a portion of the advisory and/or program fee, whether on an ongoing or a one-time basis, in its sole discretion. In the event a client terminates an advisory agreement with JWM, any unearned fees resulting from payments made by clients in advance will be refunded to the client. Likewise, in the event JWM bills clients in arrears for services that have already been rendered, JWM will prorate such fees up to the termination date of the advisory agreement. All Jessup Wealth Management advisory program fees are negotiable. Clients may also be billed on a fixed fee basis rather than using one of the firm’s standard fee schedules as may be agreed to by the 8  firm and the client. Platform fees (if applicable), transaction charges and other account-related fees assessed by the account custodian, Commonwealth, or JWM are not negotiable. Jessup Wealth Management may waive all or a portion of the advisory program and/or program fee, whether on an ongoing or a one-time basis, in its sole discretion. In the event a client terminates an advisory agreement with Jessup Wealth Management, any unearned fees resulting from payments made by clients in advance will be refunded to the client. Likewise, in the event Jessup Wealth Management bills clients in arrears for services that have already been rendered, Jessup Wealth Management will prorate such fees up to the termination date of the advisory agreement. Financial Planning Programs Financial Planning Services Our standard fees for financial planning services are as follows: Service Customized Personal Financial Plan Updated to Customized Personal Financial Plan Outside Account Recommendations Complex Analysis and Advice* Fee $500 $250 $125 $400 per hour *Services falling under “Complex Analysis and Advice” are beyond the scope of normal planning services and/or proactive management of your portfolio. Authorization is obtained in advance for work done in these scenarios. Retirement Plan Consulting The Commonwealth Retirement Plan Consulting Program provides clients with the option of paying an annual fee for ongoing services based on a percentage of assets under advisement, a flat fee, or an hourly rate not to exceed $500. The fee amount a client will pay is negotiable between the client and the advisor and will be associated with all services provided by the advisor under the Retirement Plan Consulting Agreement. Fees may be paid directly from qualified plan assets or may be direct billed, as agreed between the client and the advisor qualified plan assets or may be direct billed, as agreed between the client and the advisor. Managed Account Fee Collection Process Managed account fees are typically automatically charged to the client’s account pursuant to instructions provided to the account custodian by JWM. Rather than automatic fee debiting from a client’s account, clients can be direct billed by writing a check to Jessup Wealth Management for the fee amount or instructing Jessup Wealth Management to charge the fee to one of the client’s other JWM accounts. Accounts in custody at NFS are billed quarterly, in advance. The initial quarterly fee will be prorated based on the number of billing days in the initial quarter. Fees are based on account value and account type and are negotiable. Deposits of funds and/or securities during a particular calendar quarter are subject to billing on a pro-rata basis. Clients who withdraw funds from a managed account during a billing period are not generally entitled to a pro rata refund unless they are terminating their managed account program client agreement. Accounts in custody at Schwab are billed monthly, in arrears. The fee is based on the average daily account balance over the billing period. 9  Jessup Wealth Management allows for the aggregation of assets among a client’s “related” managed accounts for purposes of determining the value of AUM and the applicable advisory fee to be paid by a client. Jessup Wealth Management reserves the right to determine whether client accounts are “related” for purposes of aggregating a client’s accounts together for a reduction in the percentage fee amount. Other Fees and Costs Clients incur certain charges in connection with certain investments, transactions, and services in your account. In many cases, Commonwealth will receive a portion of these fees and charges or add a markup to the charges clients would otherwise pay to generate additional revenue for Commonwealth. The actual fees and charges that clients will incur are dependent upon the type of account and the nature and quantity of the transactions that occur, the services that are provided, or the positions that are held in the account. Additional fees and charges that clients will typically pay include, but are not limited to: • Mutual fund or money market 12b-1 fees, subtransfer agent fees, and distributor fees • Mutual fund and money market management fees and administrative expenses • Mutual fund transaction and redemption fees • Certain deferred sales charges on mutual funds purchased or transferred into the account • Other transaction charges and service fees • IRA and qualified retirement plan fees • Other charges that may be required by law • Brokerage account fees and charges Fees, which is available on Commonwealth’s website Information describing the brokerage fees and charges that are applicable to a Jessup Wealth Management managed account is provided on Commonwealth’s Schedule of Miscellaneous Account and Service at www.commonwealth.com/clients/media/Commonwealth_Brokerage_Fee_Schedule.pdf. Mutual Fund Share Classes In most cases, mutual fund companies offer multiple share classes of the same mutual fund. Some share classes of a fund charge higher internal expenses, whereas other share classes of a fund charge lower internal expenses. Institutional and advisory share classes typically have lower expense ratios and are less costly for a client to hold than Class A shares or other share classes that are eligible for purchase in an advisory account. Mutual funds that offer institutional share classes, advisory share classes, and other share classes with lower expense ratios are available to investors who meet specific eligibility requirements that are described in the mutual fund’s prospectus or its statement of additional information. These eligibility requirements include, but may not be limited to, investments meeting certain minimum dollar amounts and accounts that the fund considers qualified fee-based programs. Depending upon the availability of particular share classes through our clearing firm, the presence of existing holdings in your account that may transfer into our firm from another institution or other factors, you may not be invested in the lowest-cost share class for one or more mutual funds in your managed account. To the extent that a particular mutual fund or funds charges so-called 12b-1 fees, those fees will be credited back to your account and not shared with our firm or our advisors. Clients should never assume that they will be invested in the share class with the lowest possible expense ratio or cost. However, the firm does not consider this a conflict of interest given that neither the firm nor its advisors earn additional compensation based on the share class of a particular mutual fund in which you may be invested. 10  Jessup Wealth Management urges clients to discuss with their advisor whether lower-cost share classes are available in their program account. Clients should also ask their advisor why the funds or other investments that will be purchased or held in their managed account are appropriate for them in consideration of their expected holding period, investment objective, risk tolerance, time horizon, financial condition, amount invested, trading frequency, the amount of the advisory fee charged, whether the client will pay transaction charges for fund purchases and sales, whether clients will pay higher internal fund expenses in lieu of transaction charges that could adversely affect long-term performance, and relevant tax considerations. Your advisor may recommend, select, or continue to hold a fund share class that charges you higher internal expenses than other available share classes for the same fund. The purchase or sale of transaction-fee (“TF”) funds available for investment through Jessup Wealth Management will result in the assessment of transaction charges to you, your advisor, Jessup Wealth Management or Commonwealth. Although no-transaction-fee (“NTF”) funds do not assess transaction charges, most NTF funds have higher internal expenses than funds that do not participate in an NTF program. These higher internal fund expenses are assessed to investors who purchase or hold NTF funds. Depending upon the frequency of trading and hold periods, NTF funds may cost you more, or may cost Jessup Wealth Management, Commonwealth, or your advisor less, than mutual funds that assess transaction charges but have lower internal expenses. In addition, the higher internal expenses charged to clients who hold NTF funds will adversely affect the long-term performance of their accounts when compared to share classes of the same fund that assess lower internal expenses. Prorated Rebate of Fees Paid in Advance In the event a client terminates an advisory agreement with Jessup Wealth Management and his or her advisor, any unearned fees resulting from advanced payments will be refunded to the client. Likewise, in the event Jessup Wealth Management bills clients in arrears for services that have already been rendered, Jessup Wealth Management will prorate such fees up to the termination date of the advisory agreement. Other Forms of Compensation When Jessup Wealth Management provides financial planning services for a client, the client typically pays for services rendered on a one-time basis, but compensation will be ongoing if a client elects to receive ongoing financial planning services. For Retirement Plan Consulting, the fee may be an hourly, flat, fixed, or asset-based fee for providing one-time, or ongoing, advisory services to a plan. For both types of services, payment may be made either at the time of the service, in advance, or in arrears. Clients should make checks payable to Jessup Wealth Management only in relation to financial planning services. Checks for Retirement Plan Consulting Services should be made payable to Commonwealth. Checks for asset management services should never be made payable to the advisor or any other entity under the control of the advisor in relation to any programs or services offered through Jessup Wealth Management. Clients who are asked or instructed by their advisor to make checks payable to the advisor or any entity under control of the advisor should contact Matthew Jessup directly for verification. Clients should be aware that, when assets are invested in shares of mutual funds, variable insurance products, and certain alternative investments within a managed account program, clients will pay investment advisory fees to Jessup Wealth Management and to the advisor for their advisory services in connection with the investments. In addition to the payments received by Jessup Wealth Management and the advisor, clients will also pay management fees, mutual fund and money market 12b-1 fees, subtransfer agent fees, mutual fund and money market administrative expenses, mutual fund transaction fees, certain deferred sales charges and redemption fees on previously purchased mutual funds, annuity 11  internal expenses and fees, and other fees charged by the investment company, insurance product, or alternative investment sponsor, which are typically charged to clients as an internal expense of the product. These internal expenses are described in the prospectus or offering document for the specific product. Clients may be able to invest directly in the investment company, insurance product, or alternative investment without incurring the investment advisory fees, platform fees, or transaction charges assessed by Jessup Wealth Management or their advisor. If a client’s assets are invested in a fee- based annuity, the client will pay both the direct management fee to Jessup Wealth Management and their advisor for the advisory services provided by Jessup Wealth Management and the advisor in connection with that investment and, indirectly, the management and other fees charged by the underlying annuity investment options, as well as the charges assessed by the insurance company for the product. Of course, clients should also be aware of the tax implications of investing, as well as of the existence of deferred sales charges or redemption fees charged by some product sponsors for positions the client subsequently sells in Jessup Wealth Management managed accounts. For California Residents: Subsection (j) of Rule 260.238 of the California Code of Regulations requires that all investment advisers disclose to their advisory clients that lower fees for comparable services may be available from other sources. For Massachusetts Residents: Massachusetts General Law Section 203A requires disclosure that information about the disciplinary history and the registration of Jessup Wealth Management and its associated persons may be obtained by contacting the Public Reference Branch of the SEC at 202.942.8090, or by contacting the Massachusetts Securities Division at One Ashburton Place, 17th Floor, Boston, MA 02108 or at 617.727.3548. Special Disclosures for ERISA Plans: In this Brochure, Jessup Wealth Management has disclosed conflicts of interest, such as receiving additional compensation from third parties (e.g., 12b-1 fees, subtransfer agent fees, and revenue sharing) for providing marketing, recordkeeping, or other services in connection with certain investments. Jessup Wealth Management, however, has adopted policies and procedures that are designed to ensure compliance with the prohibited transaction rules under the Employee Retirement Income Security Act of 1974 (“ERISA”), as amended. For example, Jessup Wealth Management has taken several steps to address the conflict of interest associated with Jessup Wealth Management’s or Jessup Wealth Management’s advisors’ receipt of compensation for services provided to ERISA plans. First, an advisor negotiates the compensation with ERISA plan sponsors or participants (“ERISA clients”) and the compensation is either an annual fee for ongoing services based on a percentage of assets under advisement, a flat fee, or an hourly rate. Second, to the extent that an advisor receives additional compensation from a third party, the advisor must report it to Jessup Wealth Management to enable the additional compensation to be offset against the fees that the ERISA clients would otherwise pay for the advisor’s services. Third, Jessup Wealth Management has established a policy not to influence any advisor’s advice or management of assets at any time or for any reason based on any compensation that Jessup Wealth Management or the advisor might receive from third parties. In no event will Jessup Wealth Management allow advisors to provide advice or manage assets for ERISA clients if they have conflicts of interest that Jessup Wealth Management believes are prohibited by ERISA. As a covered service provider to ERISA plans, Jessup Wealth Management will comply with the U.S. Department of Labor regulations on fee disclosures, effective July 16, 2011 (or such other date as provided by the Department). Thus, Jessup Wealth Management and its advisors will disclose (i) direct compensation received from ERISA clients; (ii) indirect compensation (e.g., 12b-1 fees) received from 12  third parties; and (iii) transaction-based compensation (e.g., commissions) or other similar compensation shared with related parties servicing the ERISA plan. These fee disclosures will be made reasonably in advance of entering into, renewing, or extending the advisory service agreement with the ERISA client. Item 6 – Performance-Based Fees and Side-By-Side Management Jessup Wealth Management does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client). Item 7 – Types of Clients Jessup Wealth Management generally provides advisory services to the following types of clients: Individuals (other than high net worth individuals) • • High net worth individuals • Pension and profit-sharing plans • Charitable organizations • Other investment advisers • Corporations or other businesses not listed above Jessup Wealth Management’s managed account programs generally have a $1,000,000 minimum investment requirement. In some cases, account balances may be combined at the household level to satisfy the account minimum. Jessup Wealth Management reserves the right to waive the minimum investment requirement for any reason in our sole discretion. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Investing in securities involves risk of loss that investors should be sure they understand and should be prepared to bear. Jessup Wealth Management primarily serves retail investors. The firm primarily manages client assets within model portfolios. A typical model consists of 15-25 individual stocks and 2-5 individual bonds or bond ETFs (exchange traded funds) but may include other securities and cash positions as deemed appropriate. Models are managed on a discretionary basis. The firm maintains an investment committee that meets regularly to consider adjustments to model portfolio allocations and positions. The final buy/sell decisions for all investments models rest with the Chief Investment Officer. There are several sources of information that Jessup Wealth Management and the advisor may use as part of the investment analysis process. These sources include, but are not limited to: • SEC filings (annual reports, prospectus, 10-K, etc.) • Company press releases • Research, software, and materials prepared by third parties • Corporate rating services • Financial publications • Prospectuses and offering materials • Product and sponsor sales materials • Sponsor due diligence meetings and product presentations As a firm, Jessup Wealth Management is agnostic to "Growth" style investing vs. "Value" investing. The 13  firm is able to weight "styles" of investment as they see fit. The firm is also agnostic to size of companies (i.e., market capitalizations). Our models are able to invest into large, medium, and small size companies at any specific weighting. This flexibility then extends to having the ability to weigh non-US stocks as it sees fit. This flexibility extends to the fixed income market to include investment and/or high yield fixed income instruments. The flexibility also extends to duration of fixed income securities. In conjunction with the above, there are a few common approaches that may be used by Jessup Wealth Management or your advisor, individually or collectively, in the course of providing advice to clients. It is important to note that there is no investment strategy that will guarantee a profit or prevent loss. Following are some common strategies employed by our firm in the management of client accounts: • Dollar Cost Averaging (“DCA”): The technique of buying a fixed dollar amount of a particular investment on a regular schedule, regardless of the share price. More shares are purchased when prices are low, and fewer shares are bought when prices are high. DCA is believed to lessen the risk of investing a large amount in a single investment at higher price. DCA strategies are not effective and do not prevent against loss in declining markets. • Asset Allocation: An investment strategy that aims to balance risk and reward by allocating assets among a variety of asset classes. At a high level, there are three main asset classes—equities (stocks), fixed income (bonds), and cash/cash equivalents—each of which has different risk and reward profiles/behaviors. Asset classes are often further divided into domestic and foreign investments, and equities are often divided into small, intermediate, and large capitalization. The general theory behind asset allocation is that each asset class will perform differently from the others in different market conditions. By diversifying a portfolio of investments among a wide range of asset classes, advisors seek to reduce the overall volatility and risk of a portfolio through avoiding overexposure to any one asset class during various market cycles. Asset allocation does not guarantee a profit or protect against loss. • Technical Analysis (aka “Charting”): A method of evaluating securities by analyzing statistics generated by market activity, such as past prices and volume. Technical analysts do not attempt to measure a security’s intrinsic value. Instead, they use charts and other tools to identify patterns that can suggest future activity. When looking at individual equities, a person using technical analysis generally believes that performance of the stock, rather than performance of the company itself, has more to do with the company’s future stock price. It is important to understand that past performance does not guarantee future results. • Fundamental Analysis: A method of evaluating a security that entails attempting to measure its intrinsic value by examining related economic, financial, and other qualitative and quantitative factors. Fundamental analysts attempt to study everything that can affect the security’s value, including macroeconomic factors (e.g., the overall economy and industry conditions) and company-specific factors (e.g., financial condition and management). The end goal of performing fundamental analysis is to produce a value that an investor can compare with the security’s current price, with the aim of figuring out what sort of position to take with that security (underpriced = buy, overpriced = sell or short). This method of security analysis is the opposite of technical analysis. • Quantitative Analysis: An analysis technique that seeks to understand behavior by using complex mathematical and statistical modeling, measurement, and research. By assigning a numerical value to variables, quantitative analysts try to replicate reality mathematically. Some believe that it can also be used to predict real-world events, such as changes in a share price. 14  • Qualitative Analysis: Securities analysis that uses subjective judgment based on non-quantifiable information, such as management expertise, industry cycles, strength of research and development, and labor relations. This type of analysis technique is different from quantitative analysis, which focuses on numbers. The two techniques, however, are often used together. PPS Select Methods of Analysis and Investment Strategies Commonwealth’s PPS Select Program is based on asset allocation concepts and modern portfolio theory. The PPS Select portfolios are designed to provide long-term, risk-adjusted returns for investors across the risk/return spectrum. Depending on the program and model selected by a client, the program may invest in open-end mutual funds, closed-end funds, ETFs, individual municipal fixed income securities, and individual equity securities managed by Commonwealth’s own Investment Management and Research team. When selecting investments for inclusion or removal from the PPS Select portfolios, the Commonwealth Investment Management and Research team conducts extensive due diligence. Commonwealth’s investment philosophy process has five steps: (1) screening, (2) evaluation, (3) analysis, (4) portfolio construction, and (5) ongoing monitoring: • Step 1—Screening: An initial screening process based on quantitative criteria is used as a starting point for further research. Its purpose is to narrow down the universe of investments that meet Commonwealth’s objective criteria. • Step 2—Evaluation: After screening, the investment (or group of investments) under consideration is evaluated by applying a scoring system based on returns that are adjusted to consider quantifiable risk. The investment is also evaluated based on its peer group ranking, benchmark relative performance, and consistency of investment management style. • Step 3—Analysis: The objective of this step is to build a solid understanding of how the investment operates. During this stage, the Investment Management team spends a great deal of time evaluating the investment’s philosophy and process to ensure that they are consistent. After the in-depth quantitative and qualitative analysis is complete, the team meets with the potential investment’s key decision makers—either on-site or over the phone—to gain a greater understanding of their process for managing the portfolio. • Step 4—Portfolio Construction: After Commonwealth’s portfolio managers have determined that the investment is attractive on a stand-alone basis, they assess how well the investment complements and fits with other PPS Select portfolio holdings. A review of certain metrics, such as excess-return correlation, is performed to reasonably ensure that holdings will perform as expected in different market environments. • Step 5—Ongoing Monitoring: The PPS Select portfolios are monitored on an ongoing basis. The Investment Management team continually conducts performance reviews, holdings-based attribution analysis, firm commentary reviews, and conference calls and meetings to determine whether a portfolio is meeting the team’s risk-adjusted return expectations and an investment’s stated objective. Risks of Loss Regardless of what investment strategy or analysis is undertaken, investing in securities involves risk of loss that clients must be prepared to bear; in fact, some investment strategies could result in total loss of your investment. Some risks may be avoided or mitigated, while others are completely unavoidable. Some of the common risks you should consider prior to investing include, but are not limited to: Market risks: The prices of, and the income generated by, the common stocks, bonds, and other 15  securities you own may decline in response to certain events taking place around the world, including those directly involving the issuers; conditions affecting the general economy; overall market changes; local, regional, or global political, social, or economic instability; governmental or governmental agency responses to economic conditions; and currency, interest rate, and commodity price fluctuations. Interest rate risks: The prices of, and the income generated by, most debt and equity securities will most likely be affected by changing interest rates and by changes in the effective maturities and credit ratings of these securities. For example, the prices of debt securities generally decline when interest rates rise and increase when interest rates fall. In addition, falling interest rates may cause an issuer to redeem, “call,” or refinance a security before its stated maturity date, which would typically result in having to reinvest the proceeds in lower-yielding securities. Credit risks: Debt securities are also subject to credit risk, which is the possibility that the credit strength of an issuer will weaken and/or an issuer of a debt security will fail to make timely payments of principal or interest and the security will go into default. Risks of investing outside the U.S.: Investments in securities issued by entities based outside the United States are often subject to the risks described above to a greater extent. Margin transactions: Securities transactions in which an investor borrows money to purchase a security, in which case the security serves as collateral on the loan, inherently have more risk than cash purchases. If the value of the shares drops sufficiently, the investor will be required to either deposit more cash into the account or sell a portion of the stock to maintain the margin requirements of the account. This is known as a “margin call.” An investor’s overall risk in accounts utilizing margin includes the amount of money invested plus the amount that was loaned to them. Tax considerations: Our strategies and investments may have unique and significant tax implications. Unless specifically agreed otherwise, and in writing, however, tax efficiency is not our primary consideration in the management of your assets. Regardless of your account size or any other factors, it is strongly recommended that you consult with a tax professional regarding the investing of your assets. Custodians and broker/dealers must report the cost basis of equities acquired in client accounts. Your custodian will default to the first in, first out (“FIFO”) accounting method for calculating the cost basis of your equity investments and average-cost for mutual fund positions. You are responsible for contacting your tax advisor to determine if this accounting method is the right choice for you. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and Commonwealth will alert your account custodian of your individually selected accounting method. Decisions about cost basis accounting methods will need to be made before trades settle, as the cost basis method cannot be changed after settlement. Risk of loss: Investing in securities involves risk of loss that you should be prepared to bear. Commonwealth and your advisor do not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. We cannot offer any guarantees or promises that your financial goals and objectives will be met. Liquidity risk: The risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or it may not be possible to sell the investment at all. Certain structured products, interval funds, and alternative investments are less liquid than securities traded on an exchange, and you should know you may not be able to sell these 16  products outside of prescribed time periods. You should consult your advisor prior to purchasing products considered illiquid and in instances where changes in your financial situation and objectives may increase your need for liquidity. Inflation risk: Security prices and portfolio returns will likely vary in response to changes in inflation and interest rates. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client’s future interest payments and principal. Inflation also generally leads to higher interest rates, which may cause the value of many types of fixed income investments to decline. Time horizon and longevity risk: Time horizon risk is the risk that your investment horizon is shortened because of an unforeseen event (e.g., the loss of your job). This may force you to sell investments that you were expecting to hold for the long term. If you must sell at a time when the markets are down, you may lose money. Longevity risk is the risk of outliving your savings. This risk is particularly relevant for people who are retired or nearing retirement. Recommendation of particular types of securities: We will recommend various types of securities and do not primarily recommend one particular type of security over another since each client has different needs and different tolerance for risk. Each type of security has its own unique set of risks associated with it, and it would not be possible to list here all the specific risks of every type of investment. Even within the same type of investment, risks can vary widely. In very general terms, however, the higher the anticipated return of an investment, the higher the risk of loss associated with the investment. Descriptions of the types of securities we may recommend to you and some of their inherent risks are provided below: • Money market funds: A money market fund is technically a security, and, as such, there is a risk of loss of principal, although it is generally rare. In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation (“FDIC”) insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or down. If it goes up, that may result in a positive outcome. If it goes down, however, and you earn less than you expected to, you may end up needing more cash. The final risk you are taking with money market funds has to do with inflation. Because money market funds are considered to be safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods of time, inflation can eat away at your returns. • Municipal securities: Municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to, the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and whether the bond can be “called” prior to maturity. When a bond is called, it may not be possible to replace it with a bond of equal character paying the same amount of interest or yield to maturity. • Bonds: Also known as corporate debt securities, bonds are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default, when the bond is set to mature, and whether the bond can be “called” prior to maturity. When a bond is called, it may not be possible to replace it with a bond of equal character paying the same rate of return. 17  • Stocks: There are numerous ways of measuring the risk of equity securities (also known simply as “equities” or “stocks”). In very broad terms, the value of a stock depends on the financial health of the company issuing it. Stock prices, however, can be affected by many other factors, including, but not limited to, the class of stock (e.g., preferred or common), the health of the market sector of the issuing company, and the overall health of the economy. In general, larger, more well-established companies (i.e., large-caps) tend to be safer than smaller start-up companies (i.e., small-caps), but the mere size of an issuer is not, by itself, an indicator of the safety of the investment. • Mutual funds and ETFs: Mutual funds and ETFs are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund’s investments in accordance with the fund’s investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) 29 rather than balancing the fund with different types of securities. ETFs differ from mutual funds in that they can be bought and sold throughout the day like stock and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are “no load,” meaning there’s no fee to buy into or sell out of the fund, other types of mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be “closed-end” or “open-end.” Open-end mutual funds continue to allow new investors indefinitely, whereas closed-end funds have a fixed number of shares to sell, which can limit their availability to new investors. • Variable annuities: A variable annuity is a form of insurance where the seller or issuer (typically an insurance company) makes a series of future payments to a buyer (annuitant) in exchange for the immediate payment of a lump sum (single-payment annuity) or a series of regular payments (regular-payment annuity). The payment stream from the issuer to the annuitant has an unknown duration based principally upon the date of death of the annuitant. At this point, the contract will terminate, and the remainder of the funds accumulated will be forfeited unless there are other annuitants or beneficiaries in the contract. Annuities can be purchased to provide an income during retirement. Unlike fixed annuities that make payments in fixed amounts or in amounts that increase by a fixed percentage, variable annuities pay amounts that vary according to the performance of a specified set of investments, typically bond and equity mutual funds. Many variable annuities typically impose asset-based sales charges or surrender charges for withdrawals within a specified period. Variable annuities may impose a variety of fees and expenses, in addition to sales and surrender charges, such as mortality and expense risk charges, administrative fees, underlying fund expenses, and charges for special features, all of which can reduce the return. • Real estate: Real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. In fact, real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. The asset class still bears a considerable amount of market risk, however. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and 18  supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or by property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. • Limited partnerships: A limited partnership is a financial affiliation that includes at least one general partner and a number of limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner has management authority and unlimited liability. The general partner runs the business and, in the event of bankruptcy, is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks is dependent on the nature of the partnership and disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities; however, like privately placed limited partnerships, their tax treatment is under a different tax regime from equities. You should speak to your tax adviser regarding their tax treatment. • Options contracts: Options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (i.e., the expiration date). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are like having a long position on a stock. Buyers of calls hope that the stock will increase substantially before the option expires. A put gives the holder 30 the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the price of the stock will fall before the option expires. Selling options is more complicated and can be even riskier. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. • Structured products: A structured product is generally a prepackaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and, to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. In addition to a fixed maturity, they have two components: a note and a derivative. The derivative component is often an option. The note provides for periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell to the investor the security or securities at a predetermined price. Other products use the derivative component to provide for a call option written by the investor that gives the buyer of the call option the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a “principal guarantee” function, which offers protection of principal if held to maturity. These products are not always FDIC insured, however; they may only be insured by the issuer and, thus, have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves a number of risks, 19  including, but not limited to, fluctuations in the price, level, or yield of underlying instruments; interest rates; currency values; and credit quality. They also involve the risk of substantial loss of principal, limits on participation in any appreciation of the underlying instrument, limited liquidity, credit risk of the issuer, conflicts of interest, and other events that are difficult to predict. Investments may also be affected by currency controls; different accounting, auditing, financial reporting, disclosure, and regulatory and legal standards and practices; expropriation (occurs when governments take away a private business from its owners); changes in tax policy; greater market volatility; different securities market structures; higher transaction costs; and various administrative difficulties, such as delays in clearing and settling portfolio transactions or in receiving payment of dividends. These risks may be heightened in connection with investments in developing countries. Investments in securities issued by entities domiciled in the United States may also be subject to many of these risks. Any of the common risks described above could adversely affect the value of your portfolio and account performance, and you can lose money. Even though these risks exist, Jessup Wealth Management and your advisor will still earn the fees and other compensation described in this Brochure. Clients should carefully consider the risks of investing and the potential that they may lose principal while Jessup Wealth Management and your advisor continue to earn fees and other forms of compensation. Your investments are not bank deposits and are not insured or guaranteed by the FDIC or any other governmental agency, entity, or person, unless otherwise noted and explicitly disclosed as such, and as such may lose value. Item 9 – Disciplinary Information Neither Jessup Wealth Management nor its management personnel have any material disciplinary action required to be reported in this section. Item 10 – Other Financial Industry Activities and Affiliations Jessup Wealth Management does not have a related person, nor does the firm or its management personnel have a relationship with any individual or entity who is a broker dealer, investment company or pooled investment vehicle, other investment adviser or financial planner, futures commission merchant or commodity pool operator, banking or thrift institution, accountant or accounting firm, lawyer or law firm, pension consultant, real estate broker, or sponsor or syndicator of a limited partnership. Advisors associated with Jessup Wealth Management are licensed insurance agents. In this role, our advisors offer insurance products to clients when appropriate. Our firm’s insurance business is an insignificant portion of our overall business; however, our advisors will earn commission compensation if you purchase insurance from them. Clients are under no obligation to purchase insurance products from our advisors and may use the insurance agent or agency of their choice to do so. Jessup Wealth Management has chosen to partner with Commonwealth to provide certain services, including but not limited to fee billing and account performance reporting, to our firm and our clients. For the services it provides, Commonwealth charges our advisors an administrative fee at the same time clients are charged asset-based management fees. The administrative fee is charged to and paid by the advisor rather than the advisor’s clients. and is calculated as a percentage of the total account assets, 20  including cash and money market positions, held by the advisor’s clients. In the same manner as we offer asset management fee discounts as your account value grows, Commonwealth offers our advisors discounts on administrative fees based on their total assets under management within Commonwealth’s PPS programs. As our advisors grow their assets in these programs, Commonwealth’s economies of scale are shared with the advisors by reducing the administrative fees that would otherwise be charged to the advisors. These potential discounts in administrative fees present a conflict of interest because they provide a financial incentive for advisors who receive the discounts to recommend Commonwealth’s PPS programs over other available managed programs that do not offer such discounts or higher payouts to advisors. On the other hand, because Commonwealth does not assess administrative fees to advisors when they use advisory programs outside of PPS, depending upon the costs and fees of a particular outside program, advisors may have a financial incentive to use one or more outside programs rather than PPS, which also creates a conflict of interest. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Pursuant to Rule 204A-1 under the Investment Advisers Act of 1940, as amended, Jessup Wealth Management has adopted a Code of Ethics that governs several conflicts of interest we have when providing our advisory services to you. Our Code of Ethics is designed to ensure that we meet our fiduciary obligations to you and to foster a culture of compliance throughout our firm. Our Code of Ethics is comprehensive and is designed to help us detect and prevent violations of securities laws and to help ensure that we always keep your interests first. We distribute our Code of Ethics to each supervised person at the time of his or her initial affiliation with our firm; we make sure it remains available to each supervised person for as long as he or she remains associated with our firm; and we ensure that updates to our Code of Ethics are communicated to each supervised person as changes are made. Our Code of Ethics sets forth certain standards of conduct and addresses conflicts of interest between our firm, our employees, our agents, our advisors, and our advisory clients. Clients and prospective clients of Jessup Wealth Management may request a copy of our Code of Ethics at any time. Jessup Wealth Management and its advisors often invest in the same securities that we recommend to clients. Jessup Wealth Management and its advisors also recommend securities to, and buy and sell securities for, client accounts at or about the same time that we buy or sell the same securities for our own accounts. These activities create a conflict of interest between us and our clients. Our firm policy prohibits “trading ahead” of clients’ transactions to the detriment of clients. When Jessup Wealth Management and its advisors are purchasing or selling securities for their own accounts, priority will be given to client transactions, or trades will be aggregated together to obtain an average execution price for the benefit of all parties. Jessup Wealth Management has implemented surveillance and exception reports that are designed to identify and correct situations in which firm or advisor transactions are intentionally placed ahead of client transactions to the detriment of clients. Item 12 – Brokerage Practices 21  The Custodians and Brokers We Use Jessup Wealth Management does not maintain physical custody of your assets; although we will be deemed to have custody of your assets under SEC rules if you give us authority to withdraw advisory fees from your account or if you provide us with authorization for money movement to third parties (see Item 15 - Custody below). Your assets must be maintained in an account at a “qualified custodian”, generally a broker dealer or other financial institution. We primarily recommend that our clients use either National Financial Services or Charles Schwab & Co., Inc. (Schwab) registered broker-dealers, members SIPC, as thequalified custodians. At times, we may utilize other qualified custodians to hold your assets. We are independently owned and operated and are not affiliated with National Financial Services or any other qualified custodian. The qualified custodian will hold your assets in a brokerage account and buy and sell securities with our instruction. While we will recommend a qualified custodian to hold your assets, you will decide whether to do so and will open the account directly at the qualified custodian with our assistance. Not all advisers require their client to use a particular broker dealer or other custodian selected by the Advisor. However, if you choose not to open an account with one of the qualified custodians we recommend, we will not be able to provide asset management services to you. Consulting services not including asset management will be available in such cases if you desire. How We Select Brokers/Custodians We seek to use a custodian/broker who will hold your assets and execute transactions on terms that are, overall, most advantageous when compared to other available providers and their services. We consider a wide range of factors, including, among others: • Combination of transaction execution services and asset custody services • Capability to execute, clear and settle trades (buy and sell securities for your account) • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, etc.) • Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], limited partnerships) • Availability of investment research and tools that assist us in making investment decisions. • Quality of services • Competitiveness of the price of those services and willingness to negotiate the prices • Reputation, financial strength, and stability • Prior service to us and our other clients • Availability of other products and services that benefit us Your Brokerage and Custody Costs For our clients’ accounts that Jessup Wealth Management maintains via National Financial Services, Jessup Wealth Management and National Financial Services generally do not charge you separately for custody services but are compensated by charging you commissions or other fees on trades that are executed or settled into your account. Commonwealth’s commission rates applicable to our client accounts were negotiated based on the condition that our clients collectively maintain a total of at least $50,000,000 of their assets in accounts at National Financial Services. For client accounts at Commonwealth, this commitment benefits you because the overall commission rates you pay are lower than they would be otherwise. Because of these factors, to minimize your trading costs, we have Commonwealth (via NFS) execute most trades for your account(s). We have determined that having Commonwealth/NFS execute most trades is consistent with our duty to seek “best execution” of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, 22  including those listed above (see “How We Select Brokers/Custodians”). Periodically, we will review alternative broker-dealers and custodians in the marketplace to ensure that the custodians we use are meeting our duty to provide best execution for our clients. Best execution does not simply mean the lowest transaction cost. When examining firms, we will compare overall expertise, cost competitiveness and financial condition. The quality of execution by the custodians we use will be reviewed using publicly available trade execution data and other sources as needed. No single criteria will validate nor invalidate a custodian, but rather, all criteria taken together will be used in evaluating the currently utilized custodian. Products and Services Available to Us from Commonwealth and Our Custodians Commonwealth Financial Network provides Jessup Wealth Management with various products and services that enable us to both serve our clients and grow our business. Commonwealth (through their disclosed clearing relationships with National Financial Services and Pershing) provide us and our clients with access to its brokerage services— trading, custody, reporting, and related services. Commonwealth also makes available various support services. Some of those services help us manage or administer our client accounts, while others help us manage and grow our business. Following is a more detailed description of Commonwealth’s support services: Services That Benefit You Commonwealth’s brokerage services include access to a broad range of investment products, execution of securities transactions by Commonwealth’s clearing firms, and custody of client assets via their clearing firms. The investment products available through Commonwealth include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like us. They provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to Schwab retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis (we don’t have to request them) and at no charge to us. Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. include Services That Do Not Directly Benefit You Commonwealth also makes available to us other products and services that benefit our firm and our advisors but do not directly benefit you or your account. These products and services assist us in investment research, both managing and administering our clients’ accounts. They Commonwealth’s and that of third parties. We use this research to service substantially all our client accounts, including accounts not maintained at Commonwealth. In addition to investment research, Commonwealth also makes available software and other technology that: 23  • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution • Provide pricing and other market data • Facilitate payment of our fees from our client accounts • Assist with back-office functions, recordkeeping, and client reporting Services That Generally Benefit Only Us Commonwealth also offers other services intended to help us manage and further develop our business enterprise. These services include: • Complementary or discounted attendance at conferences and events • Consulting on technology, compliance, legal and business needs • Publications and conferences on practice management and business succession Our Interest in Commonwealth’s Services Our relationship with Commonwealth requires that we maintain a certain level of assets within Commonwealth’s PPS program and/or our own asset management program. This creates an incentive to recommend that you establish and maintain your account with Commonwealth, based on our interest in receiving Commonwealth’s services that benefit our business rather than based on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. To mitigate the conflict, this disclosure is provided to you. As a fiduciary, we must act in your best interests. We believe that our selection of National Financial Services or Pershing (via Commonwealth) as custodian and broker is in the best interests of our clients and conduct regular reviews of our relationship with Commonwealth to ensure this remains the case. Our choice to maintain a relationship with Commonwealth is primarily supported by the scope, quality, and price of Commonwealth’s services (see “How We Select Brokers/Custodians”) and not Commonwealth’s services that benefit only us. Block Trading Policy Jessup Wealth Management may aggregate (“bunch”) transactions in the same security on behalf of more than one client to strive for best execution and to possibly reduce the price per share. However, aggregated or bunched orders will not reduce the transaction costs to participating clients. Typically, the process of aggregating client orders is done to achieve better execution, to negotiate more favorable commission rates or to allocate orders among clients on a more equitable basis to avoid differences in prices and transaction fees or other transaction costs that might be obtained when orders are placedndependently. Jessup Wealth Management conducts aggregated transactions in a manner designed to ensure that no participating client is favored over another client. Participating clients will obtain the average share price per share for the security executed that day. To the extent the aggregated order is not filled in its entirety and when possible, securities purchased or sold in an aggregated transaction will be allocated pro-rata to the participating client accounts in proportion to the size of the orders placed for each account. The amount of securities may be increased or decreased to avoid holding odd-lot or a small number of shares for particular clients. It should be noted that Jessup Wealth Management does not receive any additional compensation or remuneration because of aggregation. Advisory clients purchase funds at net asset value. Soft Dollars Jessup Wealth Management does not use commissions to pay for research and brokerage services (i.e., 24  soft dollar transactions). Research, along with other products and services other than trade execution, are available to Jessup Wealth Management on a cash basis from various vendors. Core Account Sweep Programs (“CASPs”) Through our relationship with Commonwealth, our firm has access to a core account sweep program (“CASP”). CASP is the core account investment vehicle for eligible accounts used to hold cash balances while awaiting reinvestment. The cash balance in your eligible accounts will be deposited automatically or “swept” into interest-bearing FDIC-insurance eligible deposit accounts at one or more FDIC-insured financial institutions The interest rates for your eligible accounts may be obtained from at www.commonwealth.com/clients/deposit-sweep-program.aspx. Specific features and account eligibility of CASP are further explained in the Disclosure Document provided to clients that participate in CASP. A current version of the CASP Disclosure Document is available at www.commonwealth.com/clients/media/BankSweepDisclosureDocument.pdf. Clients should note that, though the default options for cash held in accounts are the core account investment vehicles, clients may at any time seek higher yields in other available investment options. Commonwealth keeps a portion of the interest paid by the bank(s) participating in CASP as a fee for providing bank sweep services. This fee reduces the rate of interest you receive on your cash in the bank sweep program. Jessup Wealth Management receives no financial benefits from the CASP program. We encourage our clients to review CASP program details to understand how Commonwealth and the program banks get paid for the sweep program and to discuss other available investment options should you wish to do so. Money Market Accounts For client assets awaiting reinvestment that are not eligible to invest in CASP, including Keogh plans, the Fidelity Government Money Market Fund (SPAXX) is the default money market fund used for accounts held at NFS. Clients may instruct their advisor to manually select a Money Class money fund rather than the default Fidelity Government Money Market Fund at any time. NTF Program Additionally, NFS offers an NTF program composed of no-load mutual funds. Participating mutual fund sponsors pay a fee to NFS to participate in this program, and a portion of this fee is shared with Commonwealth. None of these additional payments is paid to Jessup Wealth Management or any advisors who sell these funds. NTF mutual funds may be purchased within an investment advisory account at no charge to the client. Clients, however, should be aware that funds available through the NTF program often contain higher internal expenses than mutual funds that do not participate in the NTF program. Commonwealth’s receipt of a portion of the fees associated with the NTF program creates a conflict of interest because Commonwealth has an incentive to make available those products that provide such compensation to NFS and Commonwealth over those mutual fund sponsors that do not make such payments to NFS and Commonwealth. While Jessup Wealth Management does not receive additional compensation from NFS or Commonwealth based on the particular investment (potentially including one or more NTF funds), Jessup Wealth Management’s menu of investment options is limited to investments made available by Commonwealth. Thus, clients may be impacted by the conflict of interest previously described in this paragraph. As stated previously, Jessup Wealth Management regularly evaluates our relationship with Commonwealth to ensure it remains appropriate for the firm and our clients. The investment advisory services provided by Jessup Wealth Management may cost the client more or 25  less than purchasing similar services separately. Clients should consider whether the appointment of Commonwealth as the sole broker/dealer may result in certain costs or disadvantages to the client because of possibly less favorable executions. Factors to consider include the type and size of the account and the client’s historical and expected account size or number of trades. Item 13 – Review of Accounts All asset management client accounts are reviewed by an Investment Advisor Representative (IAR) of the firm on an annual basis, or when changes in client circumstances or market conditions warrant. Securities held in managed accounts are regularly reviewed by the firm’s Chief Investment Officer and Director of Research and Trading. Clients will be provided statements at least quarterly directly from account custodian where your assets are maintained. Additionally, you will receive confirmations of all transactions directly from account custodian. All non-retirement accounts and retirement accounts for those clients taking distributions will receive an annual tax reporting statement. In addition, at least once a year, all managed account clients will receive a performance report. You should compare the report with statements received directly from the account custodian(s). Should there be any discrepancy; the account custodian’s report will prevail. Item 14 – Client Referrals and Other Compensation Jessup Wealth Management receives an economic benefit from Commonwealth in the form of the support, products and services Commonwealth makes available to Jessup Wealth Management and other investment advisors whose clients maintain their accounts on Commonwealth’s platform. These products and services, how they benefit us, and the related conflicts of interest, are described in Item 12 of this brochure. Our access to Commonwealth’s products and services is not conditioned on our firm or our advisors giving particular investment advice, such as buying particular securities for our clients. Commonwealth offers our firm and our firm’s advisory representatives one or more forms of financial benefits based on our advisory representatives’ total AUM held at Commonwealth or financial assistance for advisory representatives transitioning from another firm to Commonwealth. The types of financial benefits that our advisory representatives may receive from Commonwealth include, but are not limited to, forgivable or unforgivable loans, enhanced payouts, and discounts or waivers on transaction, platform, and account fees; technology fees; research package fees; financial planning software fees; administrative fees; brokerage account fees; account transfer fees; licensing and insurance costs; and the cost of attending conferences and events. The enhanced payouts, discounts, and other forms of financial benefits that advisory representatives may receive from Commonwealth are a conflict of interest and provide a financial incentive for advisory representatives to select Commonwealth as broker/dealer for your accounts over other broker/dealers from which they may not receive similar financial benefits. We attempt to mitigate this conflict of interest by disclosing the conflict in this brochure and engaging in a regular review of our relationship with Commonwealth to ensure the relationship continues to be appropriate in all respects for our firm’s clients. During their previous affiliation with Commonwealth as investment adviser representatives and during the firm’s current relationship with Commonwealth as a service provider, Commonwealth provided loans to the principals of Jessup Wealth Management, Matthew Jessup and Mark McEvily. As of December 31, 2024, the balance on those loans stood at approximately $1 million. (the “Notes”). The Notes are not forgivable and are scheduled to be repaid to Commonwealth between 2026 and 2029. The funds were 26  used for a variety of purposes, including conducting a renovation of the firm’s office space and purchasing the practice of a retiring advisor. The existence of the Notes presents a conflict of interest in that our firm and the firm’s principals have a financial incentive to maintain our relationship with Commonwealth as the balance on the Notes becomes due immediately upon termination of our affiliation with Commonwealth. However, to the extent we direct clients to Commonwealth for programs or services, it is because the firm believes that it is in that client’s best interest to do so given our regular review of the firm’s relationship with Commonwealth. Jessup Wealth Management produces a podcast entitled The Independent Advisors Podcast. The firm receives revenue from individuals and entities that wish to sponsor its podcast. Though the revenue received is not a significant portion of the firm’s overall revenue, the receipt of sponsorship revenue itself is a conflict of interest. To the extent that a podcast sponsor offers investment products (e.g. a mutual fund sponsor, etc.), it is firm policy that we do not select products for use in client portfolios as a result of the receipt or potential receipt of any monetary or non-monetary assistance. Further, the firm’s due diligence of a product does not take into consideration any assistance it may receive. For all sponsors, Jessup Wealth Management does not necessarily endorse, explicitly or implicitly, the use of the sponsor’s products or services. The choice of whether to use a sponsor's products or services will remain solely with the firm’s clients or your advisor. In all cases, clients retain the responsibility for evaluating whether it is prudent to join a class action or to opt out. In connection with the acquisition of Commonwealth by LPL Financial Holdings, Inc. (“LPLH”), on November 18, 2025, Jessup Wealth Management received loans that are forgiven over a multi-year term, subject to continued affiliation with Commonwealth, LPL Financial, LLC (“LPL”), a subsidiary of LPLH, or LPLH’s affiliates after the acquisition. The existence of the loans presents a conflict of interest in that our firm and/or our advisors have a financial incentive to maintain our relationship with LPL and/or Commonwealth. However, to the extent we direct clients to LPL and/or Commonwealth for services, it is because the firm believes that it is in that client’s best interest to do so, given our regular review of the firm’s relationship with Commonwealth and/or LPL. We receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab. You do not pay more for assets maintained at Schwab because of these arrangements. However, we benefit from the referral arrangement because the cost of these services would otherwise be borne directly by us. You should consider these conflicts of interest when selecting a custodian. The products and services provided by Schwab, how they benefit us, and the related conflicts of interest are described above (see Item 12—Brokerage Practices). Jessup Wealth Management’s Use of Solicitors Jessup Wealth Management utilizes a referral program designed to compensate outside professionals or firms, such as attorneys, accountants, or other broker/dealers and investment advisers, for referring your advisory business to Jessup Wealth Management. These professionals or firms are known as “promoters.” If your advisory account is referred by a promoter to Jessup Wealth Management, Jessup Wealth Management will pay a portion of the advisory fee you pay us to the promoter, typically for as long as you maintain an advisory relationship with us, to compensate the promoter for the referral. Jessup Wealth Management will not charge a client who is referred to our firm by a promoter any amount for the cost of obtaining the client, which is in addition to the fee normally charged by Jessup Wealth Management for its investment advisory services. Such referral arrangements are disclosed to clients at the time of the solicitation via execution of a Promoter Disclosure Statement or similar document that outlines the nature and amount of the compensation we pay to the promoter and whether the promoter 27  is affiliated with or related to Jessup Wealth Management. Item 15 – Custody Jessup Wealth Management does not maintain physical custody of your assets. Under SEC rules, we are deemed to have custody of your assets if you authorize us to instruct your account custodian to deduct our advisory fees directly from your account, or if you provide us with authorization to transfer funds from your account to a third party. Jessup Wealth Management maintains a relationship with Commonwealth who, as described previously in this brochure, maintains a primary clearing relationship for the execution of client transactions with NFS as the account custodian, and a secondary clearing relationship for the execution of client transactions with Pershing as the account custodian. Clients who establish a managed account with Jessup Wealth Management utilizing Commonwealth as the broker/dealer of record will receive custodial account statements directly from the respective custodian that holds those assets, such as NFS, Pershing, or a direct product sponsor. Clients should carefully review the statements they receive from their account custodians and should promptly report material discrepancies to Jessup Wealth Management. Jessup Wealth Management’s clients may also receive portfolio summary or performance reporting for their managed accounts from Jessup Wealth Management or their advisor that are in addition to the account statements clients receive directly from the respective account custodian. Jessup Wealth Management urges you to compare the account statements you receive from your account custodian with any account summary statements or reports you receive from us or your advisor. Although account holdings and asset valuations should generally match, for purposes of calculating performance and account valuations on your account, our summary or performance reporting month-end market values sometimes differs from custodial account statement month-end market values. The three most common reasons why these values may differ are differences in the way accrued interest is calculated, the date upon which “as of” dividends and capital gains are reported, and settlement date versus trade date valuations. If you believe there are material discrepancies between your custodial statement and the summary statements or reports you receive from Jessup Wealth Management or your advisor, please contact Jessup Wealth Management directly at the phone number or email listed on the cover page of this brochure. Item 16 – Investment Discretion Jessup Wealth Management renders investment advice to all its managed account clients on a discretionary basis, pursuant to written authorization granted by the client to the firm. This authorization grants to Jessup Wealth Management and your advisor the discretion to buy, sell, exchange, convert, or otherwise trade in securities and/or insurance products, and to execute orders for such securities and/or insurance products with or through any distributor, issuer, or broker/dealer as Jessup Wealth Management may select. Your advisor may, without obtaining your consent, determine which products to purchase or sell for your managed account, as well as when to purchase or sell such products, and the prices to be paid. Neither Jessup Wealth Management nor your advisor, however, is granted authority to take possession of your assets. Clients may impose reasonable restrictions on their managed account, including, but not limited to, the type, nature, or specific names of securities to be bought, sold, or held in their managed account, as well as the type, nature, or specific names of securities that may not be bought, sold, or held in their managed 28  account. Clients grant Jessup Wealth Management and their advisor discretionary trading authority over their accounts when the accounts are opened. As a matter of firm policy, neither Jessup Wealth Management nor its advisors have or will accept the authority to file class action claims on behalf of clients. This policy reflects Jessup Wealth Management’s recognition that it does not have the requisite expertise to advise clients about participating in class actions. Jessup Wealth Management and its advisors have no obligation to determine if securities held by the client are subject to a pending or resolved class action settlement or verdict. Jessup Wealth Management and its advisors also have no duty to evaluate a client’s eligibility or to submit a claim to participate in the proceeds of a securities class action settlement or verdict. Furthermore, Jessup Wealth Management and its advisors have no obligation or responsibility to initiate litigation to recover damages on behalf of clients who may have been injured because of actions, misconduct, or negligence by corporate management of issuers whose securities are held by clients. The decision to participate in a class action or to sign a release of claims when submitting a proof of claim may involve the exercise of legal judgment, which is beyond the scope of services provided to clients by Jessup Wealth Management. Item 17 – Voting Client Securities As a matter of firm policy, and in accordance with this Brochure and our advisory client agreements, neither Jessup Wealth Management nor our advisors have or will accept the authority to vote proxies on behalf of advisory clients in any situation where Jessup Wealth Management or the adviser acts as investment adviser to the client. Jessup Wealth Management or our advisors may, but are not obligated to, provide advice to clients regarding the clients’ voting of proxies. In all cases, clients must either retain the responsibility for receiving and voting proxies for any and all securities maintained in their managed accounts, or they must appoint a third-party investment adviser or other person who is not associated with Jessup Wealth Management to vote proxies for their managed accounts. In the event the advisor chooses to provide advice to clients designed to assist the client in deciding how to vote their proxies, the advisor has a fiduciary duty to disclose to the client any material conflicts of interest the advisor may have with respect to such advice. In all cases, Jessup Wealth Management or the advisor will send, or will cause to be sent, all such proxy and legal proceedings information and documents it receives to the client, so that the client may take whatever action the client deems advisable under the circumstances. Item 18 – Financial Information Jessup Wealth Management neither has a financial commitment that would impair its ability to meet its contractual and fiduciary commitments to clients, nor has Jessup Wealth Management been the subject of a bankruptcy proceeding. 29