KUCHARO WEALTH

Item 1: Cover Page Form ADV Part 2B - Brochure Supplement Kucharo Wealth, LLC 1422 South Tryon Street, Suite 300 Charlotte, North Carolina 28203 (704) 251-9550 Dated: March 5, 2026 For Bradley A. Kucharo CEO and Chief Compliance Officer This brochure supplement provides information about Bradley A. Kucharo that supplements the Kucharo Wealth, LLC ("KW") brochure. A copy of that brochure precedes this supplement. Please contact Bradley A. Kucharo if the KW brochure is not included with this supplement or if you have any questions about the contents of this supplement. Additional information about Bradley A. Kucharo is available on the SEC's website at www.adviserinfo.sec.gov which can be found using the identification number 6909050.  Item 2: Educational Background and Business Experience Bradley A. Kucharo Born: 1981 Educational Background 2005 - MAc., University of Iowa 2004 - B.B.A., University of Iowa Business Experience 01/2024 - Present, Kucharo Wealth, LLC, Founder, Owner, Investment Adviser Representative, CEO, and CCO 08/2022 - 01/2024, The Vanguard Group, Registered Representative & Investment Adviser Representative 07/2017 - 06/2022, Brightworth, LLC, Outside Solicitor 11/2007 - 06/2022, John K. McGill & Company, Inc., Senior Tax and Business Planning Advisor Professional Designation(s) CFP® (Certified Financial Planner): Bradley A. Kucharo is certified for financial planning services in the United States by Certified Financial Planner Board of Standards, Inc. ("CFP Board"). Therefore, Bradley A. Kucharo may refer to themself as a CERTIFIED FINANCIAL PLANNER™ professional or a CFP® professional, and Bradley A. Kucharo may use these and CFP Board's other certification marks (the "CFP Board Certification Marks"). The CFP® certification is voluntary. No federal or state law or regulation requires financial planners to hold the CFP® certification. You may find more information about the CFP® certification at www.cfp.net CFP® professionals have met CFP Board's high standards for education, examination, experience, and ethics. To become a CFP® professional, an individual must fulfill the following requirements: • Education - Earn a bachelor's degree or higher from an accredited college or university and complete CFP Board-approved coursework at a college or university through a CFP Board Registered Program. The coursework covers the financial planning subject areas CFP Board has determined are necessary for the competent and professional delivery of financial planning services, as well as a comprehensive financial plan development capstone course. A candidate may satisfy some of the coursework requirements through other qualifying credentials. • Examination - Pass the comprehensive CFP® Certification Examination. The examination is designed to assess an individual's ability to integrate and apply a broad base of financial planning knowledge in the context of real-life financial planning situations. • Experience - Complete 6,000 hours of professional experience related to the personal financial planning process, or 4,000 hours of apprenticeship experience that meets additional requirements. • Ethics - Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP® Professionals Seeking Reinstatement and agree to be bound by CFP Board's Code of Ethics and Standards of Conduct ("Code and Standards"), which sets forth the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements to remain certified and maintain the right to continue to use the CFP Board Certification Marks: • Ethics - Commit to complying with CFP Board's Code and Standards. This includes a commitment to CFP Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests of the client, at all times when providing financial advice and financial planning. CFP Board may sanction a CFP® professional who does not abide by this commitment, but CFP Board does not guarantee a CFP®  professional's services. A client who seeks a similar commitment should obtain a written engagement that includes a fiduciary obligation to the client. • Continuing Education - Complete 30 hours of continuing education every two years to maintain competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with developments in financial planning. Two of the hours must address the Code and Standards. Certified Public Accountant (CPA): CPAs are licensed and regulated by their state boards of accountancy. While state laws and regulations vary, the education, experience and testing requirements for licensure as a CPA generally include minimum college education (150 credit hours with at least a baccalaureate degree and a concentration in accounting), minimum experience levels (most states require at least one year of experience providing services that involve the use of accounting, attest, compilation, management advisory, financial advisory, tax or consulting skills, all of which must be achieved under the supervision of or verification by a CPA), and successful passage of the Uniform CPA Examination. In order to maintain a CPA license, states generally require the completion of 40 hours of continuing professional education (CPE) each year (or 80 hours over a two year period or 120 hours over a three year period). Additionally, all American Institute of Certified Public Accountants (AICPA) members are required to follow a rigorous Code of Professional Conduct which requires that they act with integrity, objectivity, due care, competence, fully disclose any conflicts of interest (and obtain client consent if a conflict exists), maintain client confidentiality, disclose to the client any commission or referral fees, and serve the public interest when providing financial services. Item 3: Disciplinary Information Bradley A. Kucharo has never been involved in an arbitration claim of any kind or been found liable in a civil, self- regulatory organization, or administrative proceeding. Item 4: Other Business Activities Bradley A. Kucharo is not involved in any outside business activities. Item 5: Additional Compensation Bradley A. Kucharo does not receive any economic benefit from any person, company, or organization in exchange for providing Clients advisory services through KW. Item 6: Supervision Bradley A. Kucharo as Chief Compliance Officer of KW, supervises the advisory activities of our firm. Bradley A. Kucharo is bound by and will adhere to the firm's policies and procedures and Code of Ethics. Clients may contact Bradley A. Kucharo at the phone number on this brochure supplement. Item 7: Requirements for State Registered Advisers Bradley A. Kucharo has NOT been involved in an arbitration, civil proceeding, self-regulatory proceeding, administrative proceeding, or a bankruptcy petition. 

Item 1: Cover Page Kucharo Wealth, LLC 1422 South Tryon Street, Suite 300 Charlotte, North Carolina 28203 (704) 251-9550 Form ADV Part 2A - Firm Brochure Dated: March 5, 2026 This Brochure provides information about the qualifications and business practices of Kucharo Wealth, LLC. If you have any questions about the contents of this Brochure, please contact us at (704) 251-9550. 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. Kucharo Wealth, LLC is a registered investment adviser. Registration does not imply a certain level of skill or training. information about Kucharo Wealth, LLC also is available on the SEC's website at Additional www.adviserinfo.sec.g which can be found using the firm's identification number, 329601.  Item 2: Material Changes This version of our Brochure dated March 5, 2026, is our initial SEC brochure filing. We are required to amend this Brochure at least annually. Since our most recent annual update to this Brochure, the following material changes have been made: • We have updated our office and mailing address to 1422 South Tryon Street, Suite 300, Charlotte, North Carolina 28203. Please note that our prior office on South Boulevard is no longer in use. • We have clarified Bradley A. Kucharo’s roles throughout the Brochure. Mr. Kucharo is the sole owner of the KW and serves as the Chief Executive Officer and the Chief Compliance Officer. • KW updated the service offering and fees for Investment Management Services. See Item 4 and 5 for further information. • KW updated the description of advisory fees charged to retirement plans to reflect that some plans will pay fees in advance of each quarter while others will pay fees in arrears for the previous quarter, depending on the platform. Additionally, the advisory fee may be calculated based on either (i) the Average Daily Balance of the plan assets for the billing period or (ii) the value of the Client’s account(s) as of the last day of the billing period. You can find our current Brochure at any time on the SEC’s public disclosure website, the Investment Adviser Public Disclosure (“IAPD”) database, located at adviserinfo.sec.gov. We may, at any time, update this Disclosure Brochure and send a copy to you with a summary of material changes, or send you only a summary of material changes that includes an offer to send you a copy of the full brochure either by email or in hard copy form. If you would like another copy of this Disclosure Brochure, please download it from the SEC website as indicated above or contact the Firm. 2  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes Item 3: Table of Contents Item 4: Advisory Business Item 5: Fees and Compensation Item 6: Performance-Based Fees and Side-By-Side Management Item 7: Types of Clients Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Item 9: Disciplinary Information Item 10: Other Financial Industry Activities and Affiliations Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Item 12: Brokerage Practices Item 13: Review of Accounts Item 14: Client Referrals and Other Compensation Item 15: Custody Item 16: Investment Discretion Item 17: Voting Client Securities Item 18: Financial Information Item 19: Requirements for State-Registered Advisers 1 2 3 4 8 12 12 12 15 16 16 17 19 20 20 21 21 21 22 3  Item 4: Advisory Business Description of Advisory Firm Kucharo Wealth, LLC is an investment adviser principally located in the state of North Carolina. We are a limited liability company founded in January of 2024. Kucharo Wealth, LLC is a SEC-registered investment advisory firm and is registered to provide advisory services in several state jurisdictions. Bradley A. Kucharo is the principal owner and serves as the Firm’s Chief Executive Officer (“CEO”) and Chief Compliance Officer ("CCO"). As used in this brochure, the words "KW," "we," "our firm," "Advisor," and "us" refer to Kucharo Wealth, LLC and the words "you," "your," and "Client" refer to you as either a client or prospective client of our firm. Types of Advisory Services KW is a fee-only firm, meaning the only compensation we receive is from our Clients for our services. We offer investment management, financial planning, educational seminars/speaking engagements, and retirement plan services. From time to time, KW recommends third-party professionals such as attorneys, accountants, tax advisors, insurance agents, or other financial professionals. Clients are never obligated to utilize any third-party professional we recommend. KW is not affiliated with, nor does KW receive any compensation from, any third-party professionals we recommend. Financial Planning Services Financial planning involves an evaluation of a Client's current and future financial state by using currently-known variables to predict future cash flows, asset values, and withdrawal plans. The key defining aspect of financial planning is that through the financial planning process, all questions, information, and analysis will be considered as they affect and are affected by the entire financial and life situation of the Client. Clients purchasing this service will receive a written report, providing the Client with a detailed financial plan designed to help achieve the Client's stated financial goals and objectives. In general, a financial plan will address some or all of the following areas of concern depending on the nature of the engagement and needs of the Client. The Client and KW will work together to select specific areas to cover. This is a non-exclusive list of the types of areas we address: • Business Planning: We provide consulting services for Clients who currently operate their own business, are considering starting a business, or are planning for an exit from their current business. Under this type of engagement, we may work with you to assess your current situation, identify your objectives, and develop a plan aimed at achieving your goals. • Cash Flow and Debt Management: We will conduct a review of your income and expenses to determine your current surplus or deficit along with advice on prioritizing how any surplus should be used or how to reduce expenses if they exceed your income. Advice may also be provided on which debts to pay off first based on factors such as the interest rate of the debt and any income tax ramifications. We may also recommend what we believe to be an appropriate cash reserve that should be considered for emergencies and other financial goals, along with a review of accounts (such as money market funds) for such reserves, plus strategies to save desired amounts. • College Savings: Includes projecting the amount that will be needed to achieve college or other post- secondary education funding goals, along with advice on ways for you to save the desired amount. Recommendations as to savings strategies are included, and, if needed, we may review your financial picture as it relates to the best way to contribute to children and grandchildren (if appropriate). • Employee Benefits Optimization: We may provide review and analysis as to whether you, as an employee, are taking the maximum advantage possible of your employee benefits. If you are a business 4  owner, we may consider and/or recommend the various benefit programs that can be structured to meet both business and personal retirement goals. • Estate Planning: This usually includes an analysis of your exposure to estate taxes and your current estate plan, which may include whether you have a will, powers of attorney, trusts, and other related documents. Our advice also typically includes ways for you to minimize or avoid future estate taxes by implementing appropriate estate planning strategies such as the use of applicable trusts. We always recommend that you consult with a qualified attorney when you initiate, update, or complete estate planning activities. We may provide you with contact information for attorneys who specialize in estate planning when you wish to hire an attorney for such purposes. From time-to-time, we may participate in meetings or phone calls between you and your attorney with your approval or request. • Financial Goals: We will help Clients identify financial goals and develop a plan to reach them. We will identify what you plan to accomplish, what resources you will need to make it happen, how much time you will need to reach the goal, and how much you should budget for your goal. • Insurance: We may review existing policies to ensure proper coverage for life, disability, long-term care, and liability. • Investment Analysis: This may involve developing an asset allocation strategy to meet Clients' financial goals and risk tolerance, providing information on investment vehicles and strategies, reviewing employee stock options, as well as assisting you in establishing your own investment account at a selected broker/dealer or custodian. The strategies and types of investments we may recommend are further discussed in Item 8 of this brochure. • Retirement Planning: Our retirement planning services may include projections of your likelihood of achieving your financial goals, typically focusing on financial independence as the primary objective. For situations where projections show less than the desired results, we may make recommendations, including those that may impact the original projections by adjusting certain variables (e.g., working longer, saving more, spending less, taking more risk with investments). If you are near retirement or already retired, advice may be given on appropriate distribution strategies to minimize the likelihood of running out of money or having to adversely alter spending during your retirement years. • Risk Management: A risk management review includes an analysis of your exposure to major risks that could have a significant adverse impact on your financial picture, such as premature death, disability, property and casualty losses, or the need for long-term care planning. Advice may be provided on ways to minimize such risks and about weighing the costs of purchasing insurance versus the benefits of doing so and, likewise, the potential cost of not purchasing insurance ("self-insuring"). • Tax Planning Strategies: Advice may include ways to minimize current and future income taxes as a part of your overall financial planning picture. For example, we may make recommendations on which type of account(s) or specific investments should be owned based in part on their "tax efficiency," with the consideration that there is always a possibility of future changes to federal, state, or local tax laws and rates that may impact your situation. We recommend that you consult with a qualified tax professional before initiating any tax planning strategy, and we may provide you with contact information for accountants or attorneys who specialize in this area if you wish to hire someone for such purposes. We may participate in meetings or phone calls between you and your tax professional with your approval. Financial Planning Services are offered on a project-based or via an ongoing engagement. 5  Project-Based Financial Planning. We provide project-based financial planning services on a limited- scope, one-time engagement for Clients looking to address specific questions or issues as well to engage in the development and delivery of a comprehensive financial plan for which the client will have the option, upon delivery of the financial plan, to continue with an ongoing financial planning engagement as discussed below. During limited scope project-based engagement, the Client may choose from one or more of the above topics to cover or other areas as requested and agreed to by KW. For Project-Based Financial Planning, the Client will be ultimately responsible for the implementation of the financial plan. Following delivery of the plan, KW will be available for eleven months to answer any questions related to the content and application of the financial plan. Ongoing Financial Planning. Ongoing financial planning is available to Clients who have engaged KW in the development and delivery of a financial plan through a project-based financial planning engagement. This service involves working one-on-one with the financial planner ("planner") through the continued implementation, maintenance, and updating of a financial plan as the Client's financial situation, needs, and objectives change. Through this ongoing arrangement, Clients are expected to collaborate with the planner to keep them informed on and assist with the implementation of their financial plan (the "plan") and any updated recommendations that have been communicated throughout the engagement. The planner will monitor the status of the plan, recommend any appropriate changes, and ensure the plan is up-to-date as the Client's situation, goals, and objectives evolve. Upon engaging the firm for financial planning, KW is responsible for reviewing and analyzing all necessary qualitative and quantitative information from the Client that is essential to understanding the Client's personal and financial circumstances including both the information previously provided in the initial planning engagement and any new information as the circumstances evolve; helping the Client prioritize certain communicated financial goals while understanding the effect that pursuing one goal may have on other potential goals; assessing the Client's current course of action and alternative courses of action to identify required changes that provide the best opportunity for the client to meet their financial goals; developing & presenting financial planning recommendations based on the aforementioned actions while including all information that was required to be considered in preparing the recommendations; and ongoing monitoring of the Client's progress toward the goals and objectives that the recommendations are based around. These components all require in-depth communication with the Client in order for the planner to maintain a financial plan and implementation strategy that provides the Client with the most appropriate options in pursuing their established goals and objectives. Investment Management Services Our firm provides continuous advice and investment management services based on the individual needs of the Client. Through personal discussions in which goals and objectives based on a Client's particular circumstances are established, we develop a Client's personal investment policy or an investment plan. We will also review and discuss a Client's prior investment history, as well as family composition and background. Account supervision is guided by the stated objectives of the Client (e.g., maximum capital appreciation, growth, income, or growth and income), as well as risk tolerance and tax considerations. We primarily advise our Clients regarding investments in stocks, bonds, mutual funds, ETFs, U.S. government and municipal securities, and cash and cash equivalents. We may also provide advice regarding investments held in Client's portfolio at the inception of our advisory relationship and/or other investment types not listed above, at the Client's request. When we provide investment management services, Clients typically grant us limited authority to buy and sell securities on a discretionary basis. Some Clients may prefer to retain us on a non-discretionary basis. For the latter Clients we will make recommendations regarding investments but will not execute any transactions until the client approves our recommendations. More information on our trading authority is explained in Item 16 of this Brochure. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. 6  We typically utilize the services of third-party investment advisers ("Outside Managers") to assist with the management of Client accounts.1 We assist Clients in selecting an appropriate allocation model, completing the Outside Manager's investor profile questionnaire, interacting with the Outside Manager, and reviewing the Outside Manager’s performance and other characteristics. Our review process and analysis of Outside Managers is further discussed in Item 8 of this Brochure. Additionally, we will meet with the Client on a periodic basis to discuss changes in their personal or financial situation, suitability, and any new or revised restrictions to be applied to the account. KW may determine that opening an account with a professional independent third-party money manager is in your best interests. These money managers typically offer many different model portfolios that are designed to meet different investment needs. We will provide you with information about the money manager, including the services they provide, the model portfolios available and the fees they charge. You will be provided with the money manager's ADV Disclosure Brochure, which you should carefully review for important details about the manager and their fees and services. You may approve or disapprove the use of the independent money manager for your account. Once you have approved the money manager, however, the Firm has discretions to allocate, re-allocate and re-balance the model portfolios held in your account. Each manager of each specific model portfolio will have discretion to determine the securities to buy and sell for the account, subject to any reasonable restrictions imposed by you. If we recommend use of an independent money manager, KW will: • Identify your investment objectives and review them on an ongoing basis • Recommend and assist in the selection of appropriate money managers • Recommend specific investment strategies offered by the money managers • Allocate, re-allocate, and re-balance the models held in your portfolio • Assist in the review of performance and progress toward your investment objectives • Recommend any appropriate changes to your investment strategy • Recommend the hiring and firing of money managers, as needed. Retirement Plan Services Our firm provides retirement plan services to employer plan sponsors on an ongoing basis. Retirement Plan Service is not available as a stand-alone service. Clients must enroll in Financial Planning Services in order to utilize our Retirement Plan Service. Generally, such services consist of assisting employer plan sponsors or plan named fiduciaries in establishing, monitoring, and reviewing their company's retirement plan. As the needs of the plan sponsor dictate, areas of advising could include: design of investment policy statement, investment review and recommendations, fee analysis, participant education, and vendor searches & analysis. In providing retirement plan services, our firm does not provide any advisory services with respect to the following types of assets: employer securities, real estate (excluding real estate funds and publicly-traded REITs), participant loans, non-publicly traded securities or assets, other illiquid investments, or brokerage window programs (collectively, "Excluded Assets"). Educational Seminars/Speaking Engagements We may provide seminars for groups seeking general advice on investments and other areas of personal finance. These seminars are purely educational in nature and do not involve the sale of any investment products. Information presented will not be based on any individual's need, nor does KW provide individualized investment advice to attendees during these seminars. Topics covered during educational seminars will be determined by the Client and KW. 1 We currently use Management, LLC, CRD No. 148222 ("GeoWealth”), which is an independent investment manager not affiliated with our firm. 7  Client Tailored Services and Client Imposed Restrictions We tailor the delivery of our services to meet the individual needs of our Clients. We consult with Clients initially and on an ongoing basis, through the duration of their engagement with us, to determine risk tolerance, time horizon and other factors that may impact the Clients' investment and/or planning needs. Clients are able to specify, within reason, any restrictions they would like to place as it pertains to individual securities and/or sectors that will be traded in their account. All such requests must be provided to KW in writing. KW will notify Clients if they are unable to accommodate any requests. Wrap Fee Programs We do not participate in wrap fee programs. Assets Under Management As of 31 December 2025, KW has $123,656,801 in discretionary assets under management, and no non- discretionary assets under management. Item 5: Fees and Compensation Please note, unless a Client has received this brochure at least 48 hours prior to signing an Advisory Contract, the Advisory Contract may be terminated by the Client within five (5) business days of signing the Advisory Contract without penalty. How we are paid depends on the type of advisory services we perform. Below is a brief description of our fees. However, you should review your executed Advisory Contract for more detailed information regarding the exact fees you will be paying. No increase to the agreed-upon advisory fees outlined in the Advisory Contract shall occur without prior written Client consent. Please note, lower fees for comparable services may be available from other sources. Project-Based Financial Planning We charge a fixed fee for Project-Based Financial Planning. Fixed fee rates range from $1,000 to $24,000, payable in one lump sum upon delivery of the plan or in monthly installments beginning upon delivery of the plan. For payments made in installments, these must be paid in full within 12 months. The fee range is dependent upon variables including the specific needs of the Client, complexity, estimated time, research, and resources required to provide services to you, among other factors we deem relevant. Fees are negotiable and the final agreed-upon fee will be outlined in your Advisory Contract. KW will not bill an amount above $500 more than 6 months or more in advance of rendering the services. Ongoing Financial Planning Ongoing Financial Planning is only available to Clients who have previously engaged KW in project-based financial planning. We charge a recurring fixed fee for Ongoing Financial Planning. Fees are paid monthly in arrears, ranging from $100 per month to $2,000 per month. The fee range is dependent upon variables including the specific needs of the Client, complexity, estimated time, research, and resources required to provide services to you, among other factors we deem relevant. Fees are negotiable, and the final agreed-upon fee will be outlined in your Advisory Contract. At no time do we require prepayment of $500 or more six months or more in advance of rendering the services. Investment Management Services (when enrolled in Financial Planning Services) The annual advisory fee is based on a percentage of assets under management and is negotiable. The annual advisory fee does not include financial planning services unless otherwise negotiated and agreed to by the advisor. Financial planning fees will be separate and in addition to the annual advisory fee. However, Clients who are also 8  engaged in our financial planning services are charged a reduced advisory fee of 0.50% on the first $1,000,000 of assets under management. The annualized fees for investment management services are based on the following fee schedule: 0.50% $0 - $1,000,000 0.45% $1,000,001 - $2,000,000 0.40% $2,000,001 - $3,000,000 0.35% $3,000,001 - $4,000,000 0.30% $4,000,001 - $5,000,000 0.25% $5,000,001 - $10,000,000 0.20% $10,000,001 and Above The annual advisory fee is paid quarterly in advance based on the value of Client's account(s) as of the last day of the billing period. The advisory fee is a blended tier. For example, for assets under management of $2,000,000, a Client would pay 0.50% on the first $1,000,000 and 0.45% on the remaining balance. The quarterly fee is determined by the following calculation: ($1,000,000 x 0.50%) + ($1,000,000 x 0.45%) + 4 = $2,375. In determining the advisory fee, we may allow accounts of members of the same household to be aggregated. KW relies on the valuation as provided by Client's custodian in determining assets under management. Our advisory fee is prorated for any partial billing periods occurring during the engagement, including the initial and terminating billing periods. Clients may make additions or withdrawals from their account at any time; however, KW reserves the right to adjust our advisory fees on a pro-rata basis on account of any such cash-flow transactions. If KW utilizes an Outside Manager, the above fee schedule includes the Outside Manager's fee. The Outside Manager will debit the Client's account for both the Outside Manager's fee, and KW's advisory fee, and will remit KW's fee to KW. The Outside Manager's advisory fees, billing schedule, and payment procedures are set forth in their separate written disclosure documents, advisory agreements, and/or the account opening documents of your account Custodian. At no point will the combined fee charged to the Client exceed 2% of assets under management. Investment Management Services (when NOT enrolled in Financial Planning Services) The annual advisory fee is based on a percentage of assets under management and is negotiable. The annual advisory fee does not include financial planning services. For clients engaging only in investment management services the following fee table applies: 1.00% $0 - $1,000,000 0.45% $1,000,001 - $2,000,000 0.40% $2,000,001 - $3,000,000 0.35% $3,000,001 - $4,000,000 0.30% $4,000,001 - $5,000,000 0.25% $5,000,001 - $10,000,000 0.20% $10,000,001 and Above 9  The annual advisory fee is paid quarterly in advance based on the value of Client's account(s) as of the last day of the billing period. The advisory fee is a blended tier. For example, for assets under management of $2,000,000, a Client would pay 1.00% on the first $1,000,000 and 0.45% on the remaining balance. The quarterly fee is determined by the following calculation: ($1,000,000 x 1.00%) + ($1,000,000 x 0.45%) + 4 = $3,625. In determining the advisory fee, we may allow accounts of members of the same household to be aggregated. KW relies on the valuation as provided by Client's custodian in determining assets under management. Our advisory fee is prorated for any partial billing periods occurring during the engagement, including the initial and terminating billing periods. Clients may make additions or withdrawals from their account at any time; however, KW reserves the right to adjust our advisory fees on a pro-rata basis on account of any such cash-flow transactions. If KW utilizes an Outside Manager, the above fee schedule includes the Outside Manager's fee. The Outside Manager will debit the Client's account for both the Outside Manager's fee and KW's advisory fee, and will remit KW's fee to KW. The Outside Manager's advisory fees, billing schedule, and payment procedures are set forth in their separate written disclosure documents, advisory agreements, and/or the account opening documents of your account Custodian. At no point will the combined fee charged to the Client exceed 2% of assets under management. Retirement Plan Services The annual advisory fee is based on a percentage of assets under management and is negotiable. The annual advisory fee does not include financial planning services. Financial planning fees will be separate and in addition to the annual advisory fee. The annualized advisory fees are based on the following fee schedule: 0.50% $0 - $1,000,000 0.45% $1,000,001 - $2,000,000 0.40% $2,000,001 - $3,000,000 0.35% $3,000,001 - $4,000,000 0.30% $4,000,001 - $5,000,000 0.25% $5,000,001 - $10,000,000 0.20% $10,000,001 and Above The annual advisory fee is paid quarterly in advance for some plans and quarterly in arrears for others, depending on the platform used by the Client. The fee may be calculated based on either (i) the Average Daily Balance of the plan assets for the billing period or (ii) the value of the Client’s account(s) as of the last day of the billing period. The advisory fee is a blended tier. For example, for assets under management of $2,000,000, a Client would pay 0.50% on the first $1,000,000 and 0.45% on the remaining balance. The quarterly fee is determined by the following calculation: ($1,000,000 x 0.50%) + ($1,000,000 x 0.45%) + 4 = $2,375. This does not include fees to other parties, such as record keepers, custodians, or third-party administrators. KW relies on the valuation as provided by Client's custodian in determining assets under management. Our advisory fee is prorated for any partial billing periods occurring during the engagement, including the initial and terminating billing periods. Educational Seminars/Speaking Engagements Seminars and speaking engagements are offered to organizations and the public on a variety of financial topics. Fees range from $1,000 to $5,000 per seminar and are negotiable. The fee range is based on the content, amount of research conducted, the number of hours of preparation needed, and the number of attendees. KW collects the 10  fee at the conclusion of the Seminar. Advisor offers its services in a virtual or in-person setting. Should the event require travel arrangements, both parties must agree to the terms of travel (i.e., cost, distance, hotel arrangements) at the start of the engagement. Fee Payment For Investment Management Services, we deduct our advisory fee from one or more account(s) held at an unaffiliated third-party custodian, as directed by the Client. Please refer to Item 15 of this Brochure regarding our policy on direct fee deduction. When an Outside Manager is used, the Outside Manager will debit the Client's account for both the Outside Manager's fee, and KW's advisory fee. For Financial Planning Services, fees are either paid by deducting the fee from one or more account(s) held at an unaffiliated third-party custodian (if the client is using Investment Management Services) or paying the fee directly by electronic funds transfer (EFT). We use an independent third-party payment processor in which the Client can securely input their payment information and pay their fee. We do not have access to the Client's banking or credit information at any time. The Client will be provided with their own secure portal in order to make payments. For Educational Seminars/Speaking Engagements, fees are paid by electronic funds transfer (EFT). We use an independent third-party payment processor in which the Client can securely input their payment information and pay their fee. We do not have access to the Client's banking or credit information at any time. The Client will be provided with their own secure portal in order to make payments. For Retirement Plan services, fees are either paid directly by the plan sponsor or deducted directly from the plan assets by the custodian, Outside Manager, or recordkeeper. Please refer to Item 15 of this Brochure regarding our policy on direct fee deduction. All retirement plan accounts, except for 401(k) retirement plan accounts, will have the fee deducted directly from the plan assets. 401(k) retirement plan accounts will be the only retirement account where the plan sponsor has the option to have the fee deducted directly from the plan assets or pay the fee directly by electronic funds transfer (EFT). We use an independent third-party payment processor in which the Client can securely input their payment information to pay their fee. We do not have access to the Client's banking or credit information at any time. The Client will be provided with their own secure portal in order to make payments. Other Types of Fees and Expenses Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which may be incurred by the Client. Clients may incur certain charges imposed by custodians, brokers, and other third parties such as custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer, and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual fund and exchange-traded funds also charge internal management fees, which are disclosed in a fund's prospectus. Such charges, fees, and commissions are exclusive of and in addition to our fee, and we shall not receive any portion of these commissions, fees, and costs. Item 12 further describes the factors that we consider in selecting or recommending custodians for Client's transactions and determining the reasonableness of their compensation (e.g., commissions). Clients may incur fees from third-party professionals such as accountants and attorneys that KW may recommend, upon Client request. Such fees are separate and distinct from KW's advisory fees. Terminations and Refunds For Investment Management services and Retirement Plan Services, the Advisory Contract may be terminated with written notice at least 30 calendar days in advance. Upon termination of the Advisory Contract, a prorated refund based on the number of days remaining in the quarter after termination will be provided to the Client. 11  For Ongoing Financial Planning services, the Advisory Contract may be terminated with written notice at least 30 calendar days in advance. Since fees are paid in arrears, no refund will be needed upon termination of the Advisory Contract. Clients will be responsible for payment of fees up to the date of termination. For Project-Based Financial Planning services, this service is not an ongoing engagement, thus upon receipt of the final fees, the Advisory Contract will automatically be terminated. Clients may terminate at any time provided written notice. If fees are paid in advance, a prorated refund will be given, if applicable, upon termination of the Advisory Contract for any unearned fee. For fees paid in arrears, Client shall be charged a pro-rata fee based upon the percentage of the work done up to the date of termination. For Educational Seminars and Speaking Engagements, Advisor or Clients may cancel the event with 30 days' advance written notice. Should the Client cancel the event within 60 days of the event (with the exception of weather or similar unforeseen causes), the Client will be responsible for reimbursement of any non-refundable travel expenses already incurred and a prorated fee for any work conducted in preparation of the event, based on the percentage of work done and the flat fee agreed upon by both parties. Should any fees collected in advance exceed the amount of work conducted, Advisor will provide a prorated refund within 30 days from the notice of termination. Sale of Securities or Other Investment Products Advisor and its supervised persons do not accept compensation for the sale of securities or other investment products including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management We do not offer performance-based fees and do not engage in side-by-side management. Item 7: Types of Clients We provide financial planning and investment management services to individuals, high net-worth individuals, pension & profit sharing plans, and small businesses. Our minimum account size requirement is $25,000 to open or maintain an account under our management. KW may reduce or waive the minimum account size requirement on a case-by-case basis. Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Below is a brief description of our methods of analysis and primary investment strategies. Methods of Analysis Fundamental analysis involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience, and expertise of the company's management, and the outlook for the company's industry. The resulting data is used to measure the true value of the company's stock compared to the current market value. The risk of fundamental analysis is that the information obtained may be incorrect and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Modern Portfolio Theory (MPT) The underlying principles of MPT are: • Investors are risk averse. The only acceptable risk is that which is adequately compensated by an expected return. Risk and investment return are related and an increase in risk requires an increased expected return. 12  • Markets are efficient. The same market information is available to all investors at the same time. The market prices every security fairly based upon this equal availability of information. • • • The design of the portfolio as a whole is more important than the selection of any particular security. The appropriate allocation of capital among asset classes will have far more influence on long-term portfolio performance than the selection of individual securities. Investing for the long-term (preferably longer than ten years) becomes critical to investment success because it allows the long-term characteristics of the asset classes to surface. Increasing diversification of the portfolio with lower correlated asset class positions can decrease portfolio risk. Correlation is the statistical term for the extent to which two asset classes move in tandem or opposition to one another. Mutual Fund and/or ETF Analysis: We look at the experience and track record of the manager of the mutual fund or ETF in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We also look at the underlying assets in a mutual fund or ETF in an attempt to determine if there is significant overlap in the underlying investments held in other funds in the Client's portfolio. In addition, we monitor the funds or ETFs in an attempt to determine if they are continuing to follow their stated investment strategy. A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a fund or ETF, managers of different funds held by the client may purchase the same security, increasing the risk to the client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the fund or ETF less suitable for the Client's portfolio. Use of Outside Managers: We may refer Clients to Third Party Investment Advisers or advisory programs ("Outside Managers"). Our analysis of Outside Managers involves the examination of the experience, expertise, investment philosophies, and past performance of the Outside Managers in an attempt to determine if that Outside Manager has demonstrated an ability to invest over a period of time and in different economic conditions. We monitor the Outside Manager's underlying holdings, strategies, concentrations, and leverage as part of our overall periodic risk assessment. Additionally, as part of our due diligence process, we survey the Outside Manager's compliance and business enterprise risks. A risk of investing with an Outside Manager who has been successful in the past is that they may not be able to replicate that success in the future. In addition, we do not control the underlying investments in an Outside Manager's portfolio. There is also a risk that an Outside Manager may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for our Clients. Moreover, as we do not control the Outside Manager's daily business and compliance operations, we may be unaware of the lack of internal controls necessary to prevent business, regulatory, or reputational deficiencies. Investment Strategies Asset Allocation In implementing our Clients' investment strategy, we begin by attempting to identify an appropriate ratio of equities, fixed income, and cash (i.e. "asset allocation") suitable to the Client's investment goals and risk tolerance. A risk of asset allocation is that the Client may not participate in sharp increases in a particular security, industry or market sector. Another risk is that the ratio of equities, fixed income, and cash will change over time due to stock and market movements and, if not corrected, will no longer be appropriate for the Client's goals. We attempt to closely monitor our asset allocation models and make changes periodically to keep in line with the target risk tolerance model. Passive and Active Investment Management We may choose investment vehicles that are considered passive, active, or a combination of both styles. 13  Passive investing involves building portfolios that are composed of various distinct asset classes. The asset classes are weighted in a manner to achieve a desired relationship between correlation, risk, and return. Funds that passively capture the returns of the desired asset classes are placed in the portfolio. Active investing involves a single manager or managers who employ some method, strategy or technique to construct a portfolio that is intended to generate returns that are greater than the broader market or a designated benchmark. Actively managed funds are also designed to reduce volatility and risk. We may engage in both passive and active investing in the Client's portfolio. However, we strive to construct portfolios of funds and individual securities that we believe will have the greatest probability for achieving our Clients' personal financial goals with the least amount of volatility and risk rather than attempt to outperform an arbitrary index or benchmark. Specific investment selections are based on a number of factors that we evaluate in order to select, what we believe to be, the highest quality funds or individual securities for our Clients. These factors include but are not limited to underlying holdings of funds, percentage weighting of holdings within funds, liquidity, tax efficiency, bid/ask spreads, and other smart/strategic beta factors. These factors may or may not result in the lowest cost ETFs and mutual funds available when utilizing funds in a Client's portfolio, but we strive to keep internal fund expenses as low as possible. Material Risks Involved All investing strategies we offer involve risk and may result in a loss of your original investment which you should be prepared to bear. Many of these risks apply equally to stocks, bonds, commodities, and any other investment or security. Material risks associated with our investment strategies are listed below. Market Risk: Market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the value of the investment regardless of the operational success of the issuer's operations or its financial condition. Strategy Risk: The Adviser's investment strategies and/or investment techniques may not work as intended. Small and Medium Cap Company Risk: Securities of companies with small and medium market capitalizations are often more volatile and less liquid than investments in larger companies. Small and medium cap companies may face a greater risk of business failure, which could increase the volatility of the Client's portfolio. Turnover Risk: Actively managed mutual funds tend to have a higher turnover rate than passive funds. A high portfolio turnover would result in higher transaction costs and in higher taxes when shares are held in a taxable account. These factors may negatively affect the account's performance. Limited markets: Certain securities may be less liquid (harder to sell or buy) and their prices may at times be more volatile than at other times. Under certain market conditions, we may be unable to sell or liquidate investments at prices we consider reasonable or favorable or find buyers at any price. Interest Rate Risk: Bond (fixed income) prices generally fall when interest rates rise, and the value may fall below par value or the principal investment. The opposite is also generally true: bond prices generally rise when interest rates fall. In general, fixed income securities with longer maturities are more sensitive to these price changes. Most other investments are also sensitive to the level and direction of interest rates. Legal or Legislative Risk: Legislative changes or Court rulings may impact the value of investments, or the securities' claim on the issuer's assets and finances. Inflation: Inflation may erode the buying power of your investment portfolio, even if the dollar value of your investments remains the same. 14  Risks Associated with Securities Apart from the general risks outlined above which apply to all types of investments, specific securities may have other risks. Common stocks may go up and down in price quite dramatically, and in the event of an issuer's bankruptcy or restructuring could lose all value. A slower-growth or recessionary economic environment could have an adverse effect on the price of all stocks. Corporate Bonds are debt securities to borrow money. Generally, issuers pay investors periodic interest and repay the amount borrowed either periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero coupon bonds, which do not pay current interest, but rather are priced at a discount from their face values and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on factors such as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the greater its interest rate risk. Exchange Traded Funds prices may vary significantly from the Net Asset Value due to market conditions. Certain Exchange Traded Funds may not track underlying benchmarks as expected. ETFs are also subject to the following risks: (i) an ETF's shares may trade at a market price that is above (premium) or below (discount) their net asset value, and an ETF purchased at a premium may ultimately be sold at a discount; (ii) trading of an ETF's shares may be halted if the listing exchange's officials deem such action appropriate, the shares are delisted from the exchange, or the activation of market-wide "circuit breakers" (which are tied to large decreases in stock prices) halts stock trading generally. The Adviser has no control over the risks taken by the underlying funds in which the Clients invest. Municipal Bonds are debt obligations generally issued to obtain funds for various public purposes, including the construction of public facilities. Municipal bonds pay a lower rate of return than most other types of bonds. However, because of a municipal bond's tax-favored status, investors should compare the relative after-tax return to the after- tax return of other bonds, depending on the investor's tax bracket. Investing in municipal bonds carries the same general risks as investing in bonds in general. Those risks include interest rate risk, reinvestment risk, inflation risk, market risk, call or redemption risk, credit risk, and liquidity and valuation risk. Mutual Funds When a Client invests in open-end mutual funds or ETFs, the Client indirectly bears its proportionate share of any fees and expenses payable directly by those funds. Therefore, the Client will incur higher expenses, many of which may be duplicative. In addition, the Client's overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). Item 9: Disciplinary Information Criminal or Civil Actions KW and its management persons have not been involved in any criminal or civil action. Administrative Enforcement Proceedings KW and its management persons have not been involved in any administrative enforcement proceedings. Self-Regulatory Organization Enforcement Proceedings KW and its management persons have not been involved in any self-regulatory organization (SRO) proceedings. 15  Item 10: Other Financial Industry Activities and Affiliations Broker-Dealer Affiliation Neither KW nor its management persons is registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. Other Affiliations Neither KW nor its management persons is registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, commodity trading advisor, or an associated person of the foregoing entities. Related Persons Neither KW nor its management persons has any relationship or arrangement with any outside financial industry related parties. Recommendations or Selections of Other Investment Advisers KW recommends Clients to Outside Managers to manage their accounts. In the event that we recommend an Outside Manager, we pay the Outside Manager’s fee from the advisory fee we charge our Clients. The Outside Manager will deduct the single fee from client account(s), keep the portion representing its fee, and remit the balance to us. In addition, Clients will receive a copy of the Outside Manager's Form ADV 2A, Firm Brochure, which also describes the Outside Manager's fee. You are not obligated, contractually or otherwise, to use the services of any Outside Manager we recommend. Moreover, KW will only recommend an Outside Manager who is properly licensed or registered as an investment adviser. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading As a fiduciary, our firm has a duty of utmost good faith to act solely in the best interests of each Client. Our Clients entrust us with their funds and personal information, which in turn places a high standard on our conduct and integrity. Our fiduciary duty is a core aspect of our Code of Ethics and represents the expected basis of all of our dealings. The firm also adheres to the Code of Ethics and Professional Responsibility adopted by the CFP® Board of Standards Inc. and accepts the obligation not only to comply with the mandates and requirements of all applicable laws and regulations but also to take responsibility to act in an ethical and professionally responsible manner in all professional services and activities. Code of Ethics Description This Code of Ethics does not attempt to identify all possible conflicts of interest, and compliance with each of its specific provisions will not shield our firm or its access persons from liability for misconduct that violates a fiduciary duty to our Clients. A summary of the Code of Ethics' Principles is outlined below. Integrity - Access persons shall offer and provide professional services with integrity. • • Objectivity - Access persons shall be objective in providing professional services to Clients. • Competence - Access persons shall provide services to Clients competently and maintain the necessary knowledge and skill to continue to do so in those areas in which they are engaged. • Fairness - Access persons shall perform professional services in a manner that is fair and reasonable to Clients, principals, partners, and employers, and shall disclose conflict(s) of interest in providing such services. 16  • Confidentiality - Access persons shall not disclose confidential Client information without the specific consent of the Client unless in response to proper legal process, or as required by law. • Professionalism - Access persons conduct in all matters shall reflect the credit of the profession. • Diligence - Access persons shall act diligently in providing professional services. We periodically review and amend our Code of Ethics to ensure that it remains current, and we require all firm access persons to attest to their understanding of and adherence to the Code of Ethics at least annually. Our firm will provide a copy of its Code of Ethics to any Client or prospective Client upon request. Investment Recommendations Involving a Material Financial Interest and Conflicts of Interest Neither our firm, its access persons, or any related person is authorized to recommend to a Client or effect a transaction for a Client, involving any security in which our firm or a related person has a material financial interest, such as in the capacity as an underwriter, adviser to the issuer, principal transaction, among others. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest Our firm, its access persons, and its related persons may buy or sell securities similar to, or different from, those we recommend to Clients. In an effort to reduce or eliminate certain conflicts of interest, our Code of Ethics may require that we restrict or prohibit access persons' transactions in specific reportable securities. Any exceptions or trading pre-clearance must be approved by KW's Chief Compliance Officer in advance of the transaction in an account. KW maintains a copy of access persons' personal securities transactions as required. Trading Securities At/Around the Same Time as Client's Securities From time to time our firm, its access persons, or its related persons may buy or sell securities for themselves at or around the same time as they buy or sell securities for Clients' account(s). To address this conflict, it is our policy that neither our firm or access persons shall have priority over Clients' accounts in the purchase or sale of securities. Item 12: Brokerage Practices Factors Used to Select Custodians KW does not have any affiliation with any custodian we recommend. Specific custodian recommendations are made to the Client based on their need for such services. We recommend custodians based on the reputation and services provided by the firm. In recommending custodians, we have an obligation to seek the "best execution" of transactions in Client accounts. The determinative factor in the analysis of best execution is not the lowest possible commission cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of the custodian's services. The factors we consider when evaluating a custodian for best execution include, without limitation, the custodian's: • Combination of transaction execution services and asset custody services (generally without a separate fee for custody); • Capability to execute, clear, and settle trades (buy and sell securities for your account); • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.); • Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds (ETFs}, etc.); • Availability of investment research and tools that assist us in making investment decisions; • Quality of services; 17  • Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices; • Reputation, financial strength, security and stability; • Prior service to us and our clients. With this in consideration, our firm recommends Charles Schwab & Co., Inc. ("Schwab"), an independent and unaffiliated SEC registered broker-dealer firm and member of the Financial Industry Regulatory Authority ("FINRA") and the Securities Investor Protection Corporation ("SIPC"). Research and Other Soft-Dollar Benefits We do not have any soft-dollar arrangements with custodians whereby soft-dollar credits, used to purchase products and services, are earned directly in proportion to the amount of commissions paid by a Client. However, as a result of being on their institutional platform, Schwab may provide us with certain services that may benefit us. Schwab Schwab Advisor Services™ is Schwab's business serving independent investment advisory firms like us. They provide our Clients and us with access to their institutional brokerage services (trading, custody, reporting and related services), many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our Clients' accounts, while others help us manage and grow our business. Schwab's support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. The benefits received by Advisor or its personnel do not depend on the number of brokerage transactions directed to Schwab. As part of its fiduciary duties to Clients, Advisor at all times must put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits by Advisor or its related persons in and of itself creates a potential conflict of interest and may indirectly influence the Advisor's choice of Schwab for custody and brokerage services. This conflict of interest is mitigated as Advisor regularly reviews the factors used to select custodians to ensure our recommendation is appropriate. Following is a more detailed description of Schwab's support services: 1. Services that benefit you. 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. 2. Services that may not directly benefit you. Schwab also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our Clients' accounts. They include investment research, both Schwab's own and that of third parties. We may use this research to service all or a substantial number of our Clients' accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that • provide access to Client account data (such as duplicate trade confirmations and account statements) facilitate trade execution and allocate aggregated trade orders for multiple Client accounts facilitate payment of our fees from our Clients' accounts • • provide pricing and other market data • • assist with back-office functions, recordkeeping, and Client reporting 3. Services that generally benefit only us. Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology, compliance, legal, and business needs • Publications and conferences on practice management and business succession 18  4. Your brokerage and custody costs. For our Clients' accounts that Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. Certain trades (for example, many mutual funds and ETFs) may not incur Schwab commissions or transaction fees. Brokerage for Client Referrals We receive no referrals from a custodian, broker-dealer or third party in exchange for using that custodian, broker- dealer or third party. Clients Directing Which Broker/Dealer/Custodian to Use Our firm recommends Clients establish account(s) at Schwab to execute transactions through. We will assist with establishing your account(s) at Schwab, however, we will not have the authority to open accounts on the Client's behalf. Not all investment advisers require their Clients to use their recommended custodian. By recommending that Clients use Schwab, we may be unable to achieve most favorable execution of Client transactions, and this practice may cost Clients more money. We base our recommendations on the factors disclosed in Item 12 herein and will only recommend custodians if we believe it's in the best interest of the Client. If Clients do not wish to utilize our recommended custodian, we permit Clients to direct brokerage. We will be added to your account through a limited trading authority. However, due to restraints from not having access to an institutional platform, we are unable to achieve most favorable execution of Client transactions. Clients directing brokerage may cost Clients more money. For example, in a directed brokerage account, the Client may pay higher brokerage commissions because we may not be able to aggregate orders to reduce transaction costs, or the Client may receive a higher transaction price at their selected custodian versus our recommended custodian. Aggregating (Block) Trading for Multiple Client Accounts Aggregating orders, batch trading, or block trading is a process where trades for the same securities are purchased or sold for several clients at approximately the same time. We do not engage in block trading. It should be noted that implementing trades on a block or aggregate basis may be less expensive for client accounts; however, it is our trading policy to implement all client orders on an individual basis. Therefore, we do not aggregate or "block" client transactions. Considering the types of investments we hold in advisory client accounts, we do not believe clients are hindered in any way because we trade accounts individually. This is because we develop individualized investment strategies for clients and holdings will vary. Our strategies are primarily developed for the long-term and minor differences in price execution are not material to our overall investment strategy. Outside Managers used by KW may block Client trades at their discretion. Their specific practices are further discussed in their ADV Part 2A, Item 12. Item 13: Review of Accounts Periodic Reviews Bradley A. Kucharo, CEO and CCO of KW, will work with Clients to obtain current information regarding their assets and investment holdings and will review this information as part of our financial planning services. KW does not provide specific reports to Clients, other than financial plans. Clients who engage us for investment management services or retirement plan services will have their account(s) reviewed continuously and regularly (on at least an annual basis) by Bradley A. Kucharo, CEO and CCO. The account(s) are reviewed with regards to the Client's investment policies and risk tolerance levels. Triggers of Reviews 19  Events that may trigger a special review would be unusual performance, addition or deletions of Client-imposed restrictions, excessive draw-down, volatility in performance, or buy and sell decisions from the firm or per Client's needs. Review Reports Clients will receive trade confirmations from the custodian(s) for each transaction in their accounts as well as monthly or quarterly statements and annual tax reporting statements from their custodian showing all activity in the accounts, such as receipt of dividends and interest. KW does not provide written performance or holdings reports to Investment Management Clients outside of what is provided directly by their custodian. Item 14: Client Referrals and Other Compensation Compensation Received by Kucharo Wealth, LLC KW is a fee-only firm that is compensated solely by its Clients. KW does not receive commissions or other sales- related compensation. Except as mentioned in Item 12 above, we do not receive any economic benefit, directly or indirectly, from any third party for advice rendered to our Clients. Client Referrals from Solicitors KW does not, directly or indirectly, compensate any person who is not advisory personnel for Client referrals. Item 15: Custody KW does not hold, directly or indirectly, Client funds or securities, or have any authority to obtain possession of them. All Client assets are held at a qualified custodian. If KW deducts its advisory fee from Client's account(s), the following safeguards will be applied: i. ii. The Client will provide written authorization to KW, permitting us to be paid directly from Client's accounts held by the custodian. The custodian will send at least quarterly statements to the Client showing all disbursements from the accounts, including the amount of the advisory fee. In jurisdictions where required, KW will send an itemized invoice to the Client at the same time it instructs the custodian to debit the advisory fee. Itemization includes the formula used to calculate the fee, the amount of assets under management the fee is based on, and the time period covered by the fee. We urge you to carefully review custodial statements and compare them to the account invoices or reports that we may provide to you and notify us of any discrepancies. Clients are responsible for verifying the accuracy of these fees as listed on the custodian's brokerage statement as the custodian does not assume this responsibility. Our invoices or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. KW can establish a Standing Letter of Authorization or other similar asset transfer authorization arrangements ("SLOA") with qualified custodians in order for us to disburse funds to accounts as specifically designated by the Client. With a SLOA, a Client can typically authorize first-party and/or third-party transfers. If transfers are third- party, KW complies with each of the requirements and conditions enumerated below: 20  1. The Client provides an instruction to the qualified custodian, in writing, that includes the Client's signature, the third party's name, and either the third party's address or the third party's account number at a custodian to which the transfer should be directed. 2. The Client authorizes KW, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time. 3. The Client's qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the Client's authorization, and provides a transfer of funds notice to the Client promptly after each transfer. 4. The Client has the ability to terminate or change the instruction to the Client's qualified custodian. 5. KW has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the Client's instruction. 6. KW maintains records showing that the third party is not a related party of KW or located at the same address as KW. 7. The Client's qualified custodian sends the Client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Item 16: Investment Discretion KW offers Investment Management Services on both a discretionary and non-discretionary basis. For those Client accounts where we provide Investment Management Services, KW has discretionary authority and limited power of attorney to determine the securities and the amount of securities to be bought or sold for a Client's account without having to obtain prior Client approval for each transaction. Investment discretion is explained to Clients in detail when an advisory relationship has commenced. At the start of the advisory relationship, the Client will execute a Limited Power of Attorney, which will grant our firm discretion over the account(s). Additionally, the discretionary relationship will be outlined in the Advisory Contract and signed by the Client. Clients may limit our discretion by requesting certain restrictions on investments. However, approval of such requests are at the firm's sole discretion. If Client enters into non-discretionary arrangements with our firm, we will obtain Client's approval prior to the execution of any transactions for Client's account(s). Client has an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis. Item 17: Voting Client Securities We do not vote Client proxies. Therefore, Clients maintain exclusive responsibility for: (1) voting proxies and (2) acting on corporate actions pertaining to the Client's investment assets. The Client shall instruct the Client's qualified custodian to forward to the Client copies of all proxies and shareholder communications relating to the Client's investment assets. If the Client would like our opinion on a particular proxy vote, they may contact us at the number listed on the cover of this brochure. In most cases, you will receive proxy materials directly from the account custodian. However, in the event we were to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we would forward you any electronic solicitation to vote proxies. Item 18: Financial Information We have no financial commitment that impairs our ability to meet contractual and fiduciary commitments to our Clients, nor have we been the subject of any bankruptcy proceeding. We do not have custody of Client funds or securities, except as disclosed in Item 15 above, or require or solicit prepayment of more than $500 in fees six months or more in advance. 21  Item 19: Requirements for State-Registered Advisers Principal Officers Bradley A. Kucharo serves as KW's CEO and CCO. Information about Bradley A. Kucharo's education, business background, and outside business activities can be found in his ADV Part 2B, Brochure Supplement attached to this Brochure. Outside Business All outside business information, if applicable, of KW is disclosed in Item 10 of this Brochure. Performance-Based Fees Neither KW or Bradley A. Kucharo is compensated by performance-based fees. Material Disciplinary Disclosures No management person at KW has ever been involved in an arbitration claim of any kind or been found liable in a civil, self-regulatory organization, or administrative proceeding. Material Relationships That Management Persons Have With Issuers of Securities KW nor Bradley A. Kucharo have any relationship or arrangement with issuers of securities. 22