LECLAIR WEALTH PARTNERS

LECLAIR WEALTH PARTNERS LLC FORM ADV PART 2A BROCHURE Item 1 – Cover Page 6515 Longshore Loop, Suite 100 Dublin, Ohio 43017 888-277-5704 www.leclairwealthpartners.com This brochure provides information about the qualifications and business practices of LeClair Wealth Partners Wealth Partners LLC. If you have any questions regarding the contents of this brochure, please do not hesitate to contact our Chief Compliance Officer, Keith Dwyer by telephone at 513-977-8196 or by email at keith.dwyer@dinsmorecomplianceservices.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. LeClair Wealth Partners Wealth Partners LLC is a registered investment adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. Additional information about LeClair Wealth Partners Wealth Partners LLC is available on the SEC’s website at www.adviserinfo.sec.gov. February 13, 2026  Item 2 – Material Changes Form ADV Part 2A requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser’s disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. The following material changes occurred since the last filing on 2/5/2025: -Item 4 and 5, added information about LeClair Wealth Partners participation in the Zoe digital platform and certain inviduals participating in broker dealer transactions -Added language throughout the Brochure about the addition of Charles Schwab & Co., Inc. and Apex (Zoe) as additional custodians -Item 8, added a description of LeClaire’s limited use of artificial intelligence and additional risks related to derivatives, hedging and artificial intelligence -Item 10, added information about certain individuals participating in broker dealer transactions through a broker dealer investment banking affiliate -Item 12 and 14, added information about benefits received from custodians  Item 3 - Table of Contents Item 1 – Cover Page ...................................................................................................................................... 1 Item 2 – Material Changes ............................................................................................................................ 2 Item 3 - Table of Contents ............................................................................................................................ 3 Item 4 - Advisory Business ........................................................................................................................... 5 A. Description of the Advisory Firm .................................................................................................... 5 B. Types of Advisory Services ............................................................................................................. 5 C. Client-Tailored Advisory Services .................................................................................................. 7 D. Information Received From Clients ................................................................................................. 7 E. Assets Under Management .............................................................................................................. 7 Item 5 - Fees and Compensation ................................................................................................................... 7 A. Financial Planning and Investment Management Services .............................................................. 8 B. Payment of Fees ............................................................................................................................. 10 C. Clients Responsible for Fees Charged by Financial Institutions and External Money Managers . 10 D. Prepayment of Fees ........................................................................................................................ 11 E. Outside Compensation for the Sale of Securities or Other Investment Products to Clients .......... 11 Item 6 - Performance-Based Fees and Side-by-Side Management ............................................................. 11 Item 7 - Types of Clients ............................................................................................................................ 12 Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss .................................................... 12 A. Methods of Analysis and Risk of Loss .......................................................................................... 12 B. Material Risks Involved ................................................................................................................. 12 Item 9 – Disciplinary Information .............................................................................................................. 18 Item 10 – Other Financial Industry Activities and Affiliations .................................................................. 18 Item 11 – Code of Ethics, Participation or Interest in Client Transactions ................................................. 19 A. Description of Code of Ethics ........................................................................................................ 19 Item 12 – Brokerage Practices .................................................................................................................... 19 A. Factors Used to Select Custodians and/or Broker-Dealers ............................................................ 20 B. Trade Aggregation ......................................................................................................................... 23 Item 13 – Review of Accounts .................................................................................................................... 23 A. Periodic Reviews ........................................................................................................................... 23 B. Other Reviews and Triggering Factors .......................................................................................... 24 C. Regular Reports ............................................................................................................................. 24 Item 14 – Client Referrals and Other Compensation .................................................................................. 24  LeClair Wealth Partners Disclosure Brochure A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients ............................ 24 B. Compensation to Non-Supervised Persons for Client Referrals .................................................... 25 Item 15 – Custody ....................................................................................................................................... 25 Item 16 – Investment Discretion ................................................................................................................. 26 Item 17 – Voting Client Securities .............................................................................................................. 26 Item 18 – Financial Information ................................................................................................................. 26 4  LeClair Wealth Partners Disclosure Brochure Item 4 - Advisory Business A. Description of the Advisory Firm LeClair Wealth Partners Wealth Partners LLC (“LeClair Wealth Partners”, “LeClair” or the “Firm”) is a limited liability company organized in the State of Ohio. LeClair Wealth Partners is an investment advisory firm registered with the United States Securities and Exchange Commission (“SEC”). LeClair Wealth Partners is owned by LeClair HoldCo LLC, a limited liability company organized in the State of Florida. LeClair HoldCo is owned by Steve LeClair. B. Types of Advisory Services LeClair Wealth Partners provides personalized financial planning and discretionary and non-discretionary investment advisory services to individuals, including high net worth individuals, and entities, including, but not limited to, family offices, trusts, estates, private foundations, and qualified retirement plans. Investment Management Services LeClair Wealth Partners offers investment management services on a discretionary basis and non- discretionary basis. All investment advice provided is customized to each client’s investment objectives and financial needs. The information provided by the client, together with any other information relating to the client’s overall financial circumstances, will be used by LeClair Wealth Partners to determine the appropriate portfolio asset allocation and investment strategy for the client. Financial planning services also are provided, depending on the needs of the client. LeClair Wealth Partners provides investment management services to clients through a wrap fee program (the “LeClair Wealth Partners Wrap Fee Program”) and non-wrap fee accounts. Non-wrap accounts are offered to allow clients to invest in opportunities that are not available on the RJA platform, typically private offerings. See LeClair Wealth Partners’ Form ADV Part 2A, Appendix 1 for additional information regarding the LeClair Wealth Partners Wrap Fee Program. The securities utilized by LeClair Wealth Partners in the LeClair Wealth Partners Wrap Fee Program and non- wrap fee client accounts mainly consist of registered mutual funds and exchange traded funds (ETFs), but we will also invest in equity securities, corporate bonds, REITS, variable annuities, private funds/alternative investments, closed end funds and structured notes, if we determine such investments fit within a client’s objectives and are in the best interest of our clients. LeClair Wealth Partners may further recommend to clients that all or a portion of their LeClair Wealth Partners Wrap Fee Program investment portfolio be managed on a discretionary basis by one or more unaffiliated money managers or investment platforms (“External Managers”). The client may be required to enter into a separate agreement with the External Manager(s), which will set forth the terms and conditions of the client’s engagement of the External Manager. LeClair Wealth Partners generally renders services to the client relative to the discretionary selection of External Managers. LeClair Wealth Partners also assists in establishing the client’s investment objectives for the assets managed by External Managers, monitors and reviews the account performance and defines any restrictions on the account. The investment management fees charged by the designated External Managers are exclusive of, and in addition to, the annual advisory fee charged by LeClair Wealth Partners. For External Managers made available through the B/D Custodian RJA, custody and securities transactions commissions are included within the LeClair 5  LeClair Wealth Partners Disclosure Brochure Wealth Partners Wrap Fee Program fee. If an External Manager is utilized that engages in brokerage transactions and/or custody services with a broker-dealer/custodian other than RJA, the fees charged by that broker-dealer/custodian will be exclusive of, and in addition to, the annual LeClair Wealth Partners Wrap Program fee. For non-wrap accounts, the client will pay all transaction and other fees associated with the external manager. LeClair Wealth Partners has entered into an investment advisory service that blends online platforms with personalized advice from your dedicated LeClair advisor. This streamlines back-office support and leverages the online platform provided by Zoe Financial, Inc. (“Zoe”) powered by the technology, brokerage and clearing of Apex Clearing Corporation (“Apex”), a FINRA-registered broker-dealer and qualified custodian. Zoe assist the Firm’s back-office with reporting, administrative services, and other services relating to the administration of client accounts. Zoe will provide administrative and management services that allow for the Firm to build its own portfolios while providing automated or manual account rebalancing. The Firm does not act as a sponsor of a wrap program, but the Zoe platform acts as a wrap program, where Zoe has wrapped its fees from those of Apex and LeClair Wealth Partners. Clients in this program will open an account on the platform and receive disclosures about Zoe’s services, fees and conflicts, including Apex fees. Financial Planning Services and Consulting Services LeClair Wealth Partners offers personal financial planning to set forth goals, objectives and implementation strategies for the client over the long-term. Depending upon individual client requirements, the financial plan services will provide recommendations regarding such things as retirement planning, educational planning, estate planning, cash flow planning, asset protection, and tax planning and insurance needs and analysis. LeClair Wealth Partners prepares and provides the financial planning client with a written financial plan and performs periodic reviews of the plan with the client, as agreed upon with the client. In addition, LeClair Wealth Partners provides financial planning services that are completed upon the delivery of the financial plan to the client. Clients should notify us promptly anytime there is a change in their financial situation, goals, objectives, or needs and/or if there is any change to the financial information initially provided to us. Also, LeClair Wealth Partners provides various administrative and consulting services to clients. These services may be provided by LeClair Wealth Partners, affiliates of LeClair Wealth Partners or other professionals/organizations sourced by LeClair Wealth Partners. The administrative and consulting services include such things as bill pay and business consulting for entrepenuers. Clients are under no obligation to implement any of the recommendations provided in their written financial plan or provided through consulting services. However, should a client decide to proceed with the implementation of the investment recommendations then the client can either have LeClair Wealth Partners implement those recommendations or utilize the services of any investment adviser or broker-dealer of their choice. LeClair Wealth Partners cannot provide any guarantees or promises that a client’s financial goals and objectives will be met. 6  LeClair Wealth Partners Disclosure Brochure Investment Management Services to Retirement Plans LeClair Wealth Partners offers discretionary and non-discretionary advisory services to qualified plans, including 401k plans. These services include, depending upon the needs of the plan client, recommending, or for discretionary clients selecting, investment options for plans to offer to participants, ongoing monitoring of a plan’s investment options, assisting plan fiduciaries in creating and/or updating the plan’s written investment policy statements, working with plan service providers, and providing general investment education to plan participants. Note for IRA and Retirement Plan Clients: When LeClair Wealth Partners provides investment advice to you regarding your retirement plan account or individual retirement account, LeClair Wealth Partners is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way LeClair Wealth Partners makes money creates some conflicts with your interests, so LeClair Wealth Partners operates under a special rule that requires LeClair Wealth Partners to act in your best interest and not put LeClair Wealth Partners’s interest ahead of yours. Note Regarding Tax or Legal Advice: In providing services, LeClair Wealth Partners does not offer or otherwise provide tax or legal advice. LeClair Wealth Partners will, at a client’s direction and approval, work with a client’s existing tax or legal professionals to assist in the provision of the services. Fees charged by any tax, legal or other third-party professionals are the responsibility of the client. LeClair Wealth Partners may refer professionals; however, there is no compensation to LeClair Wealth Partners for these referrals, and clients are under no obligation to use the referred service providers. C. Client-Tailored Advisory Services Clients may impose reasonable restrictions on the management of their accounts if LeClair Wealth Partners determines, in its sole discretion, that the conditions would not materially impact the performance of a management strategy or prove overly burdensome for LeClair Wealth Partners’s management efforts. D. Information Received From Clients LeClair Wealth Partners will not assume any responsibility for the accuracy or the information provided by clients. LeClair Wealth Partners is not obligated to verify any information received from a client or other professionals (e.g., attorney, accountant) designated by a client, and LeClair Wealth Partners is expressly authorized by the client to rely on such information provided. Under all circumstances, clients are responsible for promptly notifying LeClair Wealth Partners in writing of any material changes to the client’s financial situation, investment objectives, time horizon, or risk tolerance. E. Assets Under Management As of 12/31/2025, the Firm managed $362,976,084 in client assets. Item 5 - Fees and Compensation 7  LeClair Wealth Partners Disclosure Brochure LeClair Wealth Partners charges fees based on a percentage of assets under management as well as fixed fees, depending on the particular types of services to be provided. The specific fees charged by LeClair Wealth Partners for services provided will be set forth in each client’s agreement. A. Financial Planning and Investment Management Services Fees for Investment Management Services In providing investment management services pursuant to the LeClair Wealth Partners Wrap Fee Program and non-wrap accounts, LeClair Wealth Partners charges an annual investment management services fee that is agreed upon with each client and set forth in an agreement executed by LeClair Wealth Partners and the client. The LeClair Wealth Partners Wrap Fee Program investment management fee and the non-wrap fee accounts are usually based on a percentage of the value of assets under management and is generally paid quarterly in advance, however, LeClair Wealth Partners is beginning to offer a flat fee option once assets reach a certain level. When a client’s account is opened, the investment management services fee is billed for the remainder of the current quarterly billing period and is based on the client’s initial contribution to the client account. Subsequent quarterly investment management services fees will be based on the client’s account value as of the last business day of the previous calendar quarter. If cash or securities, or a combination thereof, amounting to at least $100,000 are deposited to or withdrawn from a LeClair Wealth Partners Wrap Fee Program client’s account, or Schwab account on an individual business day in the first two months of the quarter, LeClair Wealth Partners will (i) assess investment management services fees to the deposited assets based on the value of the assets on the date of deposit for the pro rata number of days remaining in the quarter, or (ii) refund prepaid LeClair Wealth Partners Wrap Fee Program investment management services fees based on the value of the assets on the date of withdrawal for the pro rata number of days remaining in the quarter. No additional LeClair Wealth Partners Wrap Fee Program investment management services fees or adjustments to previously assessed LeClair Wealth Partners Wrap Fee Program investment management services fees will be made in connection with deposits or withdrawals that occur during the last month of the quarter. For purposes of LeClair Wealth Partners investment management services fee calculation, LeClair Wealth Partners utilizes third party sources, such as pricing services, custodians, fund administrators, and client- provided sources. For purposes of fee calculation, the asset value of LeClair Wealth Partner client accounts include cash and cash equivalents, as well as margined securities. LeClair Wealth Partners does not reduce LeClair Wealth Partners investment management fees for margin borrowing, regardless of whether the assets are in cash or other securities. LeClair Wealth Partners has a financial incentive to recommend that clients borrow money for the purchase of additional securities for the client’s account managed by LeClair Wealth Partners or otherwise not liquidate some or all the assets LeClair Wealth Partners manages. LeClair Wealth Partners addresses this conflict of interest by this disclosure and working to ensure that any recommendation to a client regarding the use of margin is suitable for the client. Following is the LeClair Wealth Partners asset based fee: FEE SCHEDULE Market Value of Assets Rate Up to $1,999,999 1.50% $2,000,000 to $4,999,999 1.25% 8  LeClair Wealth Partners Disclosure Brochure $5,000,000 to $9,999,999 1.00% $10,000,000 to $24,999,999 0.75% $25,000,000 to $49,999,999 0.50% $50,000,000 to $99,999,999 0.35% $100,000,000 and above 0.25% The percentage for the highest range of Managed Asset value achieved applies to all Managed Assets, not just Managed Assets within that range. There are clients of LeClair Wealth Partners who were clients of an unaffiliated investment adviser at which current LeClair Wealth Partners personnel served as investment adviser representatives that pay a higher fee for investment management services. LeClair Wealth Partners’s policy is to include all related client accounts, specifically the accounts of direct family members sharing the same residence address, for purposes of determining a client’s market value of assets. Fees for Financial Planning and Consulting Services Clients that are receiving financial planning and consulting services only are charged a fixed fee ranging from $5,000 to $250,000, depending upon the complexity of a client’s plan and services provided. In the alternative clients that are receiving financial planning and consulting services only may be charged an hourly fee rate up to $500.00. For clients receiving ongoing financial planning services the annual fee is charged quarterly. For financial planning services that are completed upon the delivery of the financial plan to the client, the fixed fee can be charged in quarterly installments, or otherwise in full upon delivery of the completed financial plan. Actual fees charged are clearly outlined in the financial planning agreement and clients receive invoices reflecting the amount of the fee due and payable. Fees for Investment Management Services to Retirement Plans Retirement plan advisory clients will be charged an annual asset-based fee of up to 1.00% and are billed in advance, pursuant to the terms of the retirement plan advisory agreement. Retirement plan fees are based on the market value of assets under management at the end of the prior calendar quarter. Fees may be negotiable depending on the size and complexity of the plan. Notwithstanding the foregoing, LeClair Wealth Partners and the client may choose to negotiate an annual advisory fee that varies from the schedule and ranges set forth above. Factors upon which a different annual advisory fee may be based include, but are not limited to, the size and nature of the relationship, the services rendered, the nature and complexity of the products and investments involved, time commitments, and travel requirements. The advisory fee charged by the Firm will apply to all of the client’s assets under management, unless specifically excluded in the client agreement. The advisory fee may include the financial planning services described above. Although LeClair Wealth Partners believes that its fees are competitive, clients should understand that lower fees for comparable services may be available from other sources and firms. Zoe Program 9  LeClair Wealth Partners Disclosure Brochure As discussed in Item 4, LeClair utilized a digital platform provided by Zoe with assets custodied by Apex. Zoe’s digital platform provides LeClair with simplified management, reporting, and service solutions amongst other technological and brokerage services (i.e., custody, trade execution, clearing and settlement by Apex). LeClair pays a fee to Zoe to participate and access the platform. Clients will pay advisory fees in accordance with their contract. Clients should review their Zoe agreement for further information regarding their fees. The investment advisory agreement between LeClair Wealth Partners and the client may be terminated at will by either LeClair Wealth Partners or the client upon written notice. LeClair Wealth Partners does not impose termination fees when the client terminates the investment advisory relationship, except when agreed upon in advance. B. Payment of Fees LeClair Wealth Partners generally deducts its advisory fee from a client’s investment account(s) held at his/her custodian. Upon engaging LeClair Wealth Partners to manage such account(s), a client grants LeClair Wealth Partners this limited authority through a written instruction to the custodian of his/her account(s). The client is responsible for verifying the accuracy of the calculation of the advisory fee; the custodian will not determine whether the fee is accurate or properly calculated. A client may utilize the same procedure for financial planning or consulting fees if the client has investment accounts held at a custodian. Although clients generally are required to have their investment advisory fees deducted from their accounts, in some cases, LeClair Wealth Partners will directly bill a client for investment advisory fees if it determines that such billing arrangement is appropriate given the circumstances. The custodian of the client’s accounts provides each client with a statement, at least quarterly, indicating separate line items for all amounts disbursed from the client's account(s), including any fees paid directly to LeClair Wealth Partners. Clients may make additions to and withdrawals from their account at any time, subject to LeClair Wealth Partners’s right to terminate an account. Additions may be in cash or securities provided that the Firm reserves the right to liquidate transferred securities or decline to accept particular securities into a client’s account. Clients may withdraw account assets at any time on notice to LeClair Wealth Partners, subject to the usual and customary securities settlement procedures. However, the Firm generally designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. LeClair Wealth Partners may consult with its clients about the options and implications of transferring securities. Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, short-term redemption fees, fees assessed at the mutual fund level (e.g. contingent deferred sales charges) and/or tax ramifications. C. Clients Responsible for Fees Charged by Financial Institutions and External Money Managers 10  LeClair Wealth Partners Disclosure Brochure The LeClair Wealth Partners Wrap Fee Program fee covers LeClair Wealth Partners’ advisory services, custody and commissions for securities transactions effected through RJA. The number of transactions made in clients’ accounts, the size of the accounts, and the securities used to construct a portfolio, as well as the commissions charged for each transaction, determines the relative cost of the LeClair Wealth Partners Wrap Fee Program versus paying for execution on a per transaction basis and paying a separate fee for advisory services. Participants in the LeClair Wealth Partners Wrap Fee Program may pay a higher or lower aggregate fee than if the investment management and brokerage services are purchased separately. LeClair Wealth Partners does not charge its clients higher advisory fees based on their trading activity, but clients should be aware that LeClair Wealth Partners may have an incentive to limit its trading activities in client accounts because LeClair Wealth Partners is charged for executed trades. LeClair Wealth Partners addresses this conflict of interest by this disclosure and by its policies and procedures which work to ensure that accounts are managed in accordance with clients’ goals and objectives without consideration of trading costs incurred by LeClair Wealth Partners. Transaction fees or “trade away” fees imposed for trades placed away from RJA, are not covered by the LeClair Wealth Partners Wrap Program Fee. Refer to LeClair Wealth Partners’ Form ADV Part 2A, Appendix 1 for additional information. In addition, for External Managers, clients should review each manager’s Form ADV 2A disclosure brochure and any contract they sign with the External Manager (in a dual contract relationship). The client is responsible for all such fees and expenses, as well as trading and custody costs of a broker-dealer/custodian other than RJA if utilized by that External Manager. Please see Item 12 of this brochure regarding brokerage practices. For non-wrap accounts, in addition to the management fee paid to LeClair Wealth Partners, the client may incur custody and execution fees charged by the custodian, as well as third party management and administration fees commonly charged by mutual funds and ETFs. D. Prepayment of Fees As noted in Item 5(B) above, LeClair Wealth Partners’s advisory fees generally are paid in advance. Upon the termination of a client’s advisory relationship, LeClair Wealth Partners will issue a refund equal to any unearned management fee for the remainder of the quarter. The client may specify how he/she would like such refund issued (i.e., a check sent directly to the client or a check sent to the client’s custodian for deposit into his/her account). E. Outside Compensation for the Sale of Securities or Other Investment Products to Clients LeClair Wealth Partners does not buy or sell securities and does not receive any compensation for securities transactions in any client account, other than the investment advisory fees noted above. However, as further described in Item 10, certain personnel of LeClair Wealth Partners, in their individual capacities, are licensed as insurance professionals and broker dealer representatives. Such persons earn commission-based compensation for selling insurance products to clients and for investment banking transactions. Item 6 - Performance-Based Fees and Side-by-Side Management LeClair Wealth Partners does not charge performance-based fees or participate in side-by-side management. Performance-based fees are fees that are based on a share of capital gains or capital appreciation of a client’s account. Side-by-side management refers to the practice of managing accounts 11  LeClair Wealth Partners Disclosure Brochure that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. LeClair Wealth Partners’s fees are calculated as described in Item 5 above. Item 7 - Types of Clients LeClair Wealth Partners offers investment advisory services to individuals, including high net worth individuals, families, family offices, trusts, businesses, charitable foundations, and retirement/profit- sharing plans. LeClair Wealth Partners does not impose a minimum portfolio size or a minimum initial investment to open an account. However, LeClair Wealth Partners does reserve the right to accept or decline a potential client for any reason in its sole discretion. Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis and Risk of Loss A primary step in LeClair Wealth Partners’s investment strategy is getting to know the clients – to understand their financial condition, risk profile, short- and long-term investment goals, tax situation, liquidity constraints – and assemble a complete picture of their financial situation. To aid in this understanding, LeClair Wealth Partners offers clients financial planning that is highly customized and tailored to the individual. This comprehensive approach is integral to the way that LeClair Wealth Partners does business. Once LeClair Wealth Partners has a true understanding of its clients’ needs and goals, the investment process can begin, and the Firm can recommend strategies and investments that it believes are aligned with the client’s goals and risk profile. LeClair Wealth Partners primarily employs fundamental analysis methods in developing investment strategies for its clients. Research and analysis from LeClair Wealth Partners is based on numerous sources, including third-party research materials and publicly-available materials, such as company annual reports, prospectuses, and press releases. LeClair Wealth Partners will employ artificial intelligence assistance in the gathering and review of materials, however, all investment decisions are ultimately made by personnel of LeClair Wealth Partners. LeClair Wealth Partners generally employs a long-term investment strategy for its clients, that is consistent with their financial goals. At times, the Firm may also buy and sell positions that are more short-term in nature, depending on the goals of the client and/or the fundamentals of the security sector or asset class. Client portfolios with similar investment objectives and asset allocation goals may own different securities and investments. The client’s portfolio size, tax sensitivity, desire for simplicity, income needs, long-term wealth transfer objectives, time horizon and choice of custodian are all factors that influence LeClair Wealth Partners’s investment recommendations. Investing in securities involves a risk of loss. A client can lose all or a substantial portion of his/her investment. A client should be willing to bear such a loss. Some investments are intended only for sophisticated investors and can involve a high degree of risk. B. Material Risks Involved 12  LeClair Wealth Partners Disclosure Brochure Investing in securities involves a significant risk of loss which clients should be prepared to bear. LeClair Wealth Partners’s investment recommendations are subject to various market, currency, economic, political and business risks, and such investment decisions will not always be profitable. Clients should be aware that there may be a loss or depreciation to the value of the client’s account. There can be no assurance that the client’s investment objectives will be obtained and no inference to the contrary should be made. Generally, the market value of equity stocks will fluctuate with market conditions, and small-stock prices generally will fluctuate more than large-stock prices. The market value of fixed income securities will generally fluctuate inversely with interest rates and other market conditions prior to maturity. Fixed income securities are obligations of the issuer to make payments of principal and/or interest on future dates, and include, among other securities: bonds, notes and debentures issued by corporations; debt securities issued or guaranteed by the U.S. government or one of its agencies or instrumentalities, or by a non-U.S. government or one of its agencies or instrumentalities; municipal securities; and mortgage-backed and asset-backed securities. These securities may pay fixed, variable, or floating rates of interest, and may include zero coupon obligations and inflation-linked fixed income securities. The value of longer duration fixed income securities will generally fluctuate more than shorter duration fixed income securities. Investments in overseas markets also pose special risks, including currency fluctuation and political risks, and it may be more volatile than that of a U.S. only investment. Such risks are generally intensified for investments in emerging markets. In addition, there is no assurance that a mutual fund or ETF will achieve its investment objective. Past performance of investments is no guarantee of future results. Additional risks involved in the securities recommended by LeClair Wealth Partners include, among others: • Stock market risk, which is the chance that stock prices overall will decline. The market value of equity securities will generally fluctuate with market conditions. Stock markets tend to move in cycles, with periods of rising prices and periods of falling prices. Prices of equity securities tend to fluctuate over the short term as a result of factors affecting the individual companies, industries or the securities market as a whole. Equity securities generally have greater price volatility than fixed income securities. • • Sector risk, which is the chance that significant problems will affect a particular sector, or that returns from that sector will trail returns from the overall stock market. Daily fluctuations in specific market sectors are often more extreme than fluctuations in the overall market. Issuer risk, which is the risk that the value of a security will decline for reasons directly related to the issuer, such as management performance, financial leverage, and reduced demand for the issuer's goods or services. • Non-diversification risk, which is the risk of focusing investments in a small number of issuers, industries or foreign currencies, including being more susceptible to risks associated with a single economic, political or regulatory occurrence than a more diversified portfolio might be. • Value investing risk, which is the risk that value stocks not increase in price, not issue the anticipated stock dividends, or decline in price, either because the market fails to recognize the stock’s intrinsic value, or because the expected value was misgauged. If the market does not recognize that the securities are undervalued, the prices of those securities might not appreciate as anticipated. They also may decline in price even though in theory they are already undervalued. Value stocks are typically less volatile than growth stocks, but may lag behind growth stocks in an up market. • Smaller company risk, which is the risk that the value of securities issued by a smaller company will go up or down, sometimes rapidly and unpredictably as compared to more widely held 13  LeClair Wealth Partners Disclosure Brochure securities. Investments in smaller companies are subject to greater levels of credit, market and issuer risk. • • Foreign (non-U.S.) investment risk, which is the risk that investing in foreign securities result in the portfolio experiencing more rapid and extreme changes in value than a portfolio that invests exclusively in securities of U.S. companies. Risks associated with investing in foreign securities include fluctuations in the exchange rates of foreign currencies that may affect the U.S. dollar value of a security, the possibility of substantial price volatility as a result of political and economic instability in the foreign country, less public information about issuers of securities, different securities regulation, different accounting, auditing and financial reporting standards and less liquidity than in the U.S. markets. Interest rate risk, which is the chance that prices of fixed income securities decline because of rising interest rates. Similarly, the income from fixed income securities may decline because of falling interest rates. • Credit risk, which is the chance that an issuer of a fixed income security will fail to pay interest and principal in a timely manner, or that negative perceptions of the issuer’s ability to make such payments will cause the price of that fixed income security to decline. • Exchange Traded Fund (ETF) risk, which is the risk of an investment in an ETF, including the possible loss of principal. ETFs typically trade on a securities exchange and the prices of their shares fluctuate throughout the day based on supply and demand, which may not correlate to their net asset values. Although ETF shares will be listed on an exchange, there can be no guarantee that an active trading market will develop or continue. Owning an ETF generally reflects the risks of owning the underlying securities it is designed to track. ETFs are also subject to secondary market trading risks. In addition, an ETF may not replicate exactly the performance of the index it seeks to track for a number of reasons, including transaction costs incurred by the ETF, the temporary unavailability of certain securities in the secondary market, or discrepancies between the ETF and the index with respect to weighting of securities or number of securities held. • Management risk, which is the risk that the investment techniques and risk analyses applied by LeClair Wealth Partners may not produce the desired results and that legislative, regulatory, or tax developments, affect the investment techniques available to LeClair Wealth Partners. There is no guarantee that a client’s investment objectives will be achieved. • • Real Estate risk, which is the risk that an investor’s investments in Real Estate Investment Trusts (“REITs”) or real estate-linked derivative instruments will subject the investor to risks similar to those associated with direct ownership of real estate, including losses from casualty or condemnation, and changes in local and general economic conditions, supply and demand, interest rates, zoning laws, regulatory limitations on rents, property taxes and operating expenses. An investment in REITs or real estate-linked derivative instruments subject the investor to management and tax risks. Investment Companies (“Mutual Funds”) risk, when an investor invests in mutual funds, the investor will bear additional expenses based on his/her pro rata share of the mutual fund’s operating expenses, including the management fees. The risk of owning a mutual fund generally reflects the risks of owning the underlying investments the mutual fund holds. • Commodity risk, generally commodity prices fluctuate for many reasons, including changes in market and economic conditions or political circumstances (especially of key energy-producing and consuming countries), the impact of weather on demand, levels of domestic production and imported commodities, energy conservation, domestic and foreign governmental regulation (agricultural, trade, fiscal, monetary and exchange control), international politics, policies of 14  LeClair Wealth Partners Disclosure Brochure OPEC, taxation and the availability of local, intrastate and interstate transportation systems and the emotions of the marketplace. The risk of loss in trading commodities can be substantial.  Cybersecurity risk, which is the risk related to unauthorized access to the systems and networks of LeClair Wealth Partners and its service providers. The computer systems, networks and devices used by LeClair Wealth Partners and service providers to us and our clients to carry out routine business operations employ a variety of protections designed to prevent damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches. Despite the various protections utilized, systems, networks or devices potentially can be breached. A client could be negatively impacted as a result of a cybersecurity breach. Cybersecurity breaches can include unauthorized access to systems, networks or devices; infection from computer viruses or other malicious software code; and attacks that shut down, disable, slow or otherwise disrupt operations, business processes or website access or functionality. Cybersecurity breaches cause disruptions and impact business operations, potentially resulting in financial losses to a client; impediments to trading; the inability by us and other service providers to transact business; violations of applicable privacy and other laws; regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or other compliance costs; as well as the inadvertent release of confidential information. Similar adverse consequences could result from cybersecurity breaches affecting issues of securities in which a client invests; governmental and other regulatory authorities; exchange and other financial market operators, banks, brokers, dealers and other financial institutions; and other parties. In addition, substantial costs may be incurred by those entities in order to prevent any cybersecurity breaches in the future.  Derivatives Risk, entails the use of derivative instruments for a variety of purposes, including hedging, risk management, portfolio management or to earn income. A derivative is a financial instrument whose value is based, in part, on the value of an underlying asset, interest rate, index or financial instrument (“reference instrument” or “underlying asset”). In this context, derivatives include but are not limited to futures, forwards, options, participatory notes, warrants, swaps and other similar instruments that are normally valued based upon another or related asset. The use of derivatives can lead to losses because of adverse movements in the price or value of the reference instrument, failure of the counterparty or tax or regulatory constraints. Prevailing interest rates and volatility levels, among other things, also affect the value of derivative instruments. A derivative instrument often has risks similar to its underlying asset and can have additional risks, including imperfect correlation between the value of the derivative and the underlying asset, risks of default by the counterparty to certain transactions, magnification of losses incurred due to changes in the market value of the securities, instruments, indices or interest rates to which the derivative instrument relates, risks that the transactions might not be liquid and risks arising from margin requirements. The use of derivatives involves risks that are different from, and possibly greater than, the risks associated with other portfolio investments. Derivatives can involve the use of highly specialized instruments that require investment techniques and risk analyses different from those associated with other portfolio investments. Certain derivative transactions give rise to a form of leverage, which magnifies the portfolio’s exposure to the underlying asset. Leverage associated with derivative transactions could cause an account to liquidate portfolio positions when it might not be advantageous to do so to satisfy its obligations or to meet earmarking or segregation requirements, including with respect to certain funds to comply with applicable SEC rules and regulations, or could cause an account’s value to be more volatile than might have been the case absent such leverage. Derivatives risk could be more significant when derivatives are used to enhance return or as a substitute for a position or security, rather than solely to hedge the risk of a position or security held by a client portfolio. Derivatives for hedging purposes might not reduce risk if they are not sufficiently correlated to the position being hedged. A decision as to whether, 15  LeClair Wealth Partners Disclosure Brochure when and how to use derivatives involves the exercise of specialized skill and judgment, and a transaction could be unsuccessful in whole or in part because of market behavior or unexpected events. Derivative instruments can be difficult to value, can be illiquid, and can be subject to wide swings in valuation caused by changes in the value of the underlying instrument. If a derivative counterparty is unable to honor its commitments, the value of a client portfolio could decline and/or the portfolio could experience delays in the return of collateral or other assets held by the counterparty. The loss on derivative transactions can substantially exceed the initial investment. Certain strategies use derivatives extensively. Derivative investments also involve the risks relating to the reference instrument. Although certain strategies seek to use derivatives to further a client’s investment objectives, there is no assurance that the use of derivatives will achieve this result.  Hedging Strategy risks, entails engaging in transactions designed to reduce the risk or to protect the value of investments, including securities and currency hedging transactions. These hedging strategies could involve a variety of derivative transactions, including transactions in forward, swap and option contracts or other financial instruments with similar characteristics, including, without limitation, forward foreign currency exchange contracts, currency and interest rate swaps, options and short sales (collectively “Hedging Instruments”). Certain risks associated with Hedging Instruments are further detailed under “Derivative Risks.” Hedging against a decline in the value of a portfolio position does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of those positions decline, but establishes other positions designed to gain from those same developments, thus offsetting the decline in the portfolio positions’ value. While these transactions can reduce the risks associated with an investment, the transactions themselves entail risks that are different from and possibly greater than, the risks associated with other portfolio investments. The use of Hedging Instruments could require investment techniques and risks analyses different from those associated with other portfolio investments. The risks posed by these transactions include, but are not limited to, interest rate risk, market risk, the risk that these complex instruments and techniques will not be successfully evaluated, monitored or priced, the risk that counterparties will default on their obligations, liquidity risk and leverage risk. Changes in liquidity can result in significant, rapid and unpredictable changes in the prices for derivatives. Thus, while the accounts might benefit from the use of Hedging Instruments, unanticipated changes in interest rates, securities prices or currency exchange rates could result in a poorer overall performance for the accounts than if they had not used such Hedging Instruments.  Artificial Intelligence risk. Artificial Intelligence is a branch of computer science focused on creating systems capable of performing taks that typically require human intelligence; this includes, among other things, methods for analyzing, modeling and understanding language as well as developing algorithms that can learn to perform various tasks. Such usage is subject to the limitations of design of the application and the sourcing of data. The use of artificial intelligence has inherent risks such as the reliance on accurate imputs, sourcing and interpretation of data, and human interpretation of results. Artificial intelligence continues to develop rapidly and it’s impossible to predict future risk that may arise from such development.  Alternative Investments / Private Funds risk, investing in alternative investments is speculative, not suitable for all clients, and intended for experienced and sophisticated investors who are willing to bear the high economic risks of the investment, which can include:      loss of all or a substantial portion of the investment due to leveraging, short-selling or other speculative investment practices; lack of liquidity in that there may be no secondary market for the investment and none expected to develop; volatility of returns; restrictions on transferring interests in the investment; potential lack of diversification and resulting higher risk due to concentration of trading 16  LeClair Wealth Partners Disclosure Brochure     authority when a single adviser is utilized; absence of information regarding valuations and pricing; delays in tax reporting; less regulation and higher fees than mutual funds; risks associated with the operations, personnel, and processes of the manager of the funds investing in alternative investments. • Closed-End Funds risk, Closed-end funds typically use a high degree of leverage. They may be diversified or non-diversified. Risks associated with closed-end fund investments include liquidity risk, credit risk, volatility and the risk of magnified losses resulting from the use of leverage. Additionally, closed-end funds may trade below their net asset value. Structured Notes risk - • • Complexity. Structured notes are complex financial instruments. Clients should understand the reference asset(s) or index(es) and determine how the note’s payoff structure incorporates such reference asset(s) or index(es) in calculating the note’s performance. This payoff calculation may include leverage multiplied on the performance of the reference asset or index, protection from losses should the reference asset or index produce negative returns, and fees. Structured notes may have complicated payoff structures that can make it difficult for clients to accurately assess their value, risk and potential for growth through the term of the structured note. Determining the performance of each note can be complex and this calculation can vary significantly from note to note depending on the structure. Notes can be structured in a wide variety of ways. Payoff structures can be leveraged, inverse, or inverse-leveraged, which may result in larger returns or losses. Clients should carefully read the prospectus for a structured note to fully understand how the payoff on a note will be calculated and discuss these issues with LeClair Wealth Partners. • • Market risk. Some structured notes provide for the repayment of principal at maturity, which is often referred to as “principal protection.” This principal protection is subject to the credit risk of the issuing financial institution. Many structured notes do not offer this feature. For structured notes that do not offer principal protection, the performance of the linked asset or index may cause clients to lose some, or all, of their principal. Depending on the nature of the linked asset or index, the market risk of the structured note may include changes in equity or commodity prices, changes in interest rates or foreign exchange rates, and/or market volatility. Issuance price and note value. The price of a structured note at issuance will likely be higher than the fair value of the structured note on the date of issuance. Issuers now generally disclose an estimated value of the structured note on the cover page of the offering prospectus, allowing investors to gauge the difference between the issuer’s estimated value of the note and the issuance price. The estimated value of the notes is likely lower than the issuance price of the note to investors because issuers include the costs for selling, structuring and/or hedging the exposure on the note in the initial price of their notes. After issuance, structured notes may not be re-sold on a daily basis and thus may be difficult to value given their complexity. • Liquidity. The ability to trade or sell structured notes in a secondary market is often very limited, as structured notes (other than exchange-traded notes known as ETNs) are not listed for trading on securities exchanges. As a result, the only potential buyer for a 17  LeClair Wealth Partners Disclosure Brochure structured note may be the issuing financial institution’s broker-dealer affiliate or the broker-dealer distributor of the structured note. In addition, issuers often specifically disclaim their intention to repurchase or make markets in the notes they issue. Clients should, therefore, be prepared to hold a structured note to its maturity date, or risk selling the note at a discount to its value at the time of sale. • Credit risk. Structured notes are unsecured debt obligations of the issuer, meaning that the issuer is obligated to make payments on the notes as promised. These promises, including any principal protection, are only as good as the financial health of the structured note issuer. If the structured note issuer defaults on these obligations, investors may lose some, or all, of the principal amount they invested in the structured notes as well as any other payments that may be due on the structured notes. Clients are advised that they should only commit assets for management that can be invested for the long term, that volatility from investing can occur, and that all investing is subject to risk. LeClair Wealth Partners does not guarantee the future performance of a client’s portfolio, as investing in securities involves the risk of loss that clients should be prepared to bear. Past performance of a security or a fund is not necessarily indicative of future performance or risk of loss. Use of External Managers LeClair Wealth Partners may select certain External Managers to manage a portion of its clients’ assets. In these situations, the success of such recommendations relies to a great extent on the External Managers’ ability to successfully implement their investment strategies. In addition, LeClair Wealth Partners generally may not have the ability to supervise the External Managers on a day-to-day basis. Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client’s evaluation of the adviser and the integrity of the adviser’s management. LeClair Wealth Partners has no information applicable to this Item. Item 10 – Other Financial Industry Activities and Affiliations Insurance Agent Activities As mentioned above in Item 5, advisory persons of LeClair Wealth Partners are licensed as insurance professionals. Such persons earn commission-based compensation for selling insurance products to clients. Insurance commissions earned by advisory persons who are insurance professionals are separate from and in addition to LeClair Wealth Partners’s advisory fee. This practice presents a conflict of interest as an advisory person who is an insurance professional has an incentive to recommend insurance products for the purpose of generating commissions rather than solely based on client needs. LeClair Wealth Partners addresses this conflict through disclosure and strives to make recommendations which are in the 18  LeClair Wealth Partners Disclosure Brochure best interests of its clients. Clients are under no obligation to purchase insurance products through any person affiliated with LeClair Wealth Partners. LeClair Wealth Partners clients should understand that lower fees and/or commissions for comparable services may be available from other insurance providers. Broker Dealer Activities Certain advisory persons of LeClair Wealth Partners are licensed as broker dealer representatives. Such persons earn commission-based compensation for broker dealer transactions. Commissions earned by advisory persons are separate from and in addition to LeClair Wealth Partners’s advisory fee. These individuals are licensed through their affiliate, LeClair Capital Partners, whos primary business is investment banking. This practice presents a conflict of interest as an advisory person who participates in investment banking have an incentive to recommend LeClair Wealth Partners for asset management services. LeClair Wealth Partners addresses this conflict through disclosure and strives to make recommendations which are in the best interests of its clients. Clients are under no obligation to purchase any products through any person affiliated with LeClair Wealth Partners. LeClair Wealth Partners clients should understand that lower fees and/or commissions for comparable services may be available from other providers. Recommendation of External Managers LeClair Wealth Partners may recommend that clients use External Managers based on clients’ needs and suitability. LeClair Wealth Partners does not receive separate compensation, directly or indirectly, from such External Managers for recommending that clients use their services. LeClair Wealth Partners does not have any other business relationships with the recommended External Managers. Item 11 – Code of Ethics, Participation or Interest in Client Transactions A. Description of Code of Ethics LeClair Wealth Partners has a Code of Ethics (the “Code”) which requires LeClair Wealth Partners’s employees (“supervised persons”) to comply with their legal obligations and fulfill the fiduciary duties owed to the Firm’s clients. Among other things, the Code of Ethics sets forth policies and procedures related to conflicts of interest, outside business activities, gifts and entertainment, compliance with insider trading laws and policies and procedures governing personal securities trading by supervised persons. Personal securities transactions of supervised persons present potential conflicts of interest with the price obtained in client securities transactions or the investment opportunity available to clients. The Code addresses these potential conflicts by prohibiting securities trades that would breach a fiduciary duty to a client and requiring, with certain exceptions, supervised persons to report their personal securities holdings and transactions to LeClair Wealth Partners for review by the Firm’s Chief Compliance Officer. The Code also requires supervised persons to obtain pre-approval of certain investments, including initial public offerings and limited offerings. LeClair Wealth Partners will provide a copy of the Code of Ethics to any client or prospective client upon request. Item 12 – Brokerage Practices 19  LeClair Wealth Partners Disclosure Brochure A. Factors Used to Select Custodians and/or Broker-Dealers LeClair Wealth Partners participates in the RJA Ambassador Program custodial platform. LeClair Wealth Partners will recommend that LeClair Wealth Partners Wrap Fee Program clients establish brokerage accounts with RJA to maintain custody of clients’ assets and to effect trades for their accounts. For non- wrap accounts we recommend Charles Schwab & Co., Inc. (“Schwab”) as the custodian. Raymond James and Associates, Inc., member New York Stock Exchange/SIPC, and Charles Schwab & Co., Inc., member SIPC, are a “qualified custodians” as that term is described in Rule 206(4)-2 of the Advisers Act. In recommending RJA and Schwab, LeClair Wealth Partners will consider a number of judgmental factors, including, without limitation: 1) clearance and settlement capabilities; 2) quality of confirmations and account statements; 3) the ability of the BD/Custodian to settle the trade promptly and accurately; 4) the financial standing, reputation and integrity of the BD/Custodian; 5) the BD/Custodian’s access to markets, research capabilities, market knowledge, and any “value added” characteristics; 6) LeClair Wealth Partners’s past experience with the BD/Custodian; and 7) LeClair Wealth Partners’s past experience with similar trades. Recognizing the value of these factors, clients may pay a brokerage commission in excess of that which another broker might have charged for effecting the same transaction. In exchange for using the services of RJA, LeClair Wealth Partners may receive, without cost, computer software and related systems support that allows LeClair Wealth Partners to monitor and service its clients’ accounts maintained with RJA. RJA also makes available to the Firm products and services that benefit the Firm but may not directly benefit the client or the client’s account. These products and services assist LeClair Wealth Partners in managing and administering client accounts. They include investment research, both RJA’s own and that of third parties. LeClair Wealth Partners may use this research to service all or some substantial number of client accounts, including accounts not maintained at RJA. In addition to investment research, RJA 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; and assist with back-office functions, recordkeeping, and client reporting.   provide pricing and other market data;   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, mutual funds and ETFs) do not incur Schwab commissions or transaction fees. Schwab is also compensated by earning interest on uninvested cash in your account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through Schwab, we have determined that having Scwab execute most or all trades is consistent with our duty to seek “best execution”. Best execution means the most favorable terms for a transaction 20  LeClair Wealth Partners Disclosure Brochure based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. 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, many of which are not 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 and at no charge to us. Following is a more detailed description of Schwab’s support services: 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 of which we might not otherwise have access or that would require a significantly higher minimum investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Services that do not benefit you. Schwab also makes available to us other products and services that benefit us but do not directly benefit you or your account. These products and services assist us in managing or administering our clients’ accounts and operating our firm. They include investment research, both Schwab’s own and that of third parties. We 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 provides access to client account data, facilitates trade execution, provides pricing and other market data, facilitates payment of our fees from our clients’ accounts and assists with back-office functions, recordkeeping, and client reporting. Services that generally only benefit us. Schwab also offers other services intended to help us manage and further develop our business. These include educational conferences, consulting on technology and business needs, consulting on legal or compliance needs. Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab also discounts or waives its fees for some of these services or pays all or a part of a third party’s fee. If you did not maintain you account with Schwab, we would be required to pay for those services from our own resources. PCM may use some or all of the services previously mentioned, which causes a conflict of interest when recommending Schwab. This conflict is mitigated by the careful consideration of the factor listed above when selecting or recommending a custodian/BD. Our interest in Schwab’s services. The availability of these services from Schwab benefits us because we do not have to produce or purchase them. We don’t have to pay for Schwab’s services. Schwab has agreed to pay for certain services on our behalf. The fact that we receive these benefits from Schwab is an incentive for us to recommend the use of Schwab rather than making such a decision based exclusively on your interest in receiving the best value in custody services and most favorable execution of your transactions. This is a conflict of interest. We believe, however, that taken in the aggregate our recommendation of Schwab as custodian and broker is in the best interest of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services and not Schwab’s services that benefit only us. RJA also offers other services intended to help us manage and further develop our business enterprise. These services include: 21  LeClair Wealth Partners Disclosure Brochure educational conferences and events; technology and business consulting; access to employee benefits providers, human capital consultants, and insurance providers.    publications and conferences on practice management and business succession; and  RJA may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to the Firm. RJA may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. RJA may also provide the Firm with other benefits such as occasional business entertainment of Firm personnel. The benefits received by LeClair Wealth Partners through its participation in the RJA and Schwab custodial platforms do not depend on the amount of brokerage transactions directed to RJA. In addition, there is no corresponding commitment made by LeClair Wealth Partners to RJA or Schwab to invest any specific amount or percentage of client assets in any specific mutual funds, securities or other investment products as a result of participation in the program. While as a fiduciary, we endeavor to act in our clients’ best interests, our recommendation that clients maintain their assets in accounts at RJA or Schwab will be based in part on the benefit to LeClair Wealth Partners of the availability of some of the foregoing products and services and not solely on the nature, cost or quality of custody and brokerage services provided by RJA and Schwab. The receipt of these benefits creates a potential conflict of interest and may indirectly influence LeClair Wealth Partners’s choice of RJA or Schwab for custody and brokerage services. LeClair Wealth Partners will periodically review its arrangements with the BD/Custodians and other broker-dealers against other possible arrangements in the marketplace as it strives to achieve best execution on behalf of its clients. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including, but not limited to, the following:     a broker-dealer’s trading expertise, including its ability to complete trades, execute and settle difficult trades, obtain liquidity to minimize market impact and accommodate unusual market conditions, maintain anonymity, and account for its trade errors and correct them in a satisfactory manner; a broker-dealer’s infrastructure, including order-entry systems, adequate lines of communication, timely order execution reports, an efficient and accurate clearance and settlement process, and capacity to accommodate unusual trading volume; a broker-dealer’s ability to minimize total trading costs while maintaining its financial health, such as whether a broker-dealer can maintain and commit adequate capital when necessary to complete trades, respond during volatile market periods, and minimize the number of incomplete trades; a broker-dealer’s ability to provide research and execution services, including advice as to the value or advisability of investing in or selling securities, analyses and reports concerning such matters as companies, industries, economic trends and political factors, or services incidental to executing securities trades, including clearance, settlement and custody; and 22  LeClair Wealth Partners Disclosure Brochure  a broker-dealer’s ability to provide services to accommodate special transaction needs, such as the broker-dealer’s ability to execute and account for client-directed arrangements and soft dollar arrangements, participate in underwriting syndicates, and obtain initial public offering shares. LeClair Wealth Partners’s clients may utilize qualified custodians other than RJA and Schwab for certain accounts and assets, particularly where clients have a previous relationship with such qualified custodians. Brokerage for Client Referrals LeClair Wealth Partners does not select or recommend BD/Custodians based solely on whether or not it may receive client referrals from a BD/Custodian or third party. Client Directed Brokerage Generally, for LeClair Wealth Partners Wrap Fee Program clients the Firm does not accept instructions to custody a client account at a specific broker-dealer other than RJA and/or direct some or all of his/her brokerage transactions to a specific broker-dealer other than RJA. In such instances a client would be disadvantaged because the LeClair Wealth Partners Wrap Fee Program fee does not cover the cost of trades executed away from RJA. For accounts at Schwab, LeClair Wealth Partners typically executes all trades through Schwab and there isn’t directed brokerage. Trade Errors LeClair Wealth Partners’s goal is to execute trades seamlessly and in the best interests of the client. In the event a trade error occurs, LeClair Wealth Partners endeavors to identify the error in a timely manner, correct the error so that the client’s account is in the position it would have been had the error not occurred, and, after evaluating the error, assess what action(s) might be necessary to prevent a recurrence of similar errors in the future. Trade errors generally are corrected through the use of a “trade error” account or similar account at RJA or Schwab, or another BD, as the case may be. In the event an error is made in a client account custodied elsewhere, LeClair Wealth Partners works directly with the broker in question to take corrective action. In all cases, LeClair Wealth Partners will take the appropriate measures to return the client’s account to its intended position. B. Trade Aggregation To the extent that the Firm determines to aggregate client orders for the purchase or sale of securities, including securities in which the Firm’s supervised persons may invest, the Firm will generally do so in a fair equitable manner in accordance with applicable rules promulgated under the Advisers Act and guidance provided by the staff of the SEC and consistent with policies and procedures established by the Firm. Item 13 – Review of Accounts A. Periodic Reviews Investment Management Account Reviews 23  LeClair Wealth Partners Disclosure Brochure While LeClair Wealth Partners accounts are monitored on an ongoing basis, LeClair Wealth Partners’s investment adviser representatives seek to have at least one annual meeting with each client to conduct a formal review of the clients’ accounts. As part of annual client meetings LeClair Wealth Partners collects, among other things, an update of the client’s life events since the last client meeting. Accounts are reviewed for consistency with the investment strategy and other parameters set forth for the account and to determine if any adjustments need to be made. Financial Planning and Consulting Services Account Reviews Upon completion of the initial financial plan, ongoing annual review services are established, if provided for in the client agreement. Generally, we meet with our clients on an annual basis; however, more frequent reviews are not uncommon. The nature of the annual review is to evaluate the client’s progress from the previous year based on their goals and objectives, and current alignment with the originally presented and agreed upon financial plan. LeClair Wealth Partners will collaborate with the client to update their financial information (i.e. insurance, investments, assets, income, expenses and beneficiaries) and craft their yearly financial planning reports. Financial planning reports are written and may consist of a net worth statement, cash flow statement, estimated tax projections, education analysis, retirement analysis, insurance needs analysis, estate tax calculation, and an investment analysis. Reviews are conducted by an advisor of LeClair Wealth Partners who is appropriately licensed to provide financial planning services. In addition, LeClair Wealth Partners provides financial planning services that are completed upon the delivery of the financial plan to the client. In such situations, LeClair Wealth Partners does not provide any ongoing reviews of the client’s financial plan. B. Other Reviews and Triggering Factors In addition to the periodic reviews described above, reviews may be triggered by changes in an account holder’s personal, tax or financial status. Other events that may trigger a review of an account are material changes in market conditions as well as macroeconomic and company- specific events. Clients are encouraged to notify LeClair Wealth Partners of any changes in his/her personal financial situation that might affect his/her investment needs, objectives, or time horizon. C. Regular Reports Written brokerage statements are generated no less than quarterly and are sent directly from the qualified custodian. These reports list the account positions, activity in the account over the covered period, and other related information. Clients are also sent confirmations following each brokerage account transaction unless confirmations have been waived. LeClair Wealth Partners may also determine to provide account statements and other reporting to clients on a periodic basis. Clients are urged to carefully review all custodial account statements and compare them to any statements and reports provided by LeClair Wealth Partners. LeClair Wealth Partners statements and reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Item 14 – Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients 24  LeClair Wealth Partners Disclosure Brochure We receive an economic benefit from RJA and Schwab in the form of the support products and services it makes available to us and other independent investment advisors who maintain their accounts at RJA and Schwab. In addition, RJA and Schwab have also agreed to pay for certain products or services for which we would otherwise have to pay once the value of our clients’ assets in accounts at Schwab reach a certain size. You do not pay more for assets maintained at RJA or Schwab as a result of these arrangements. However, we benefit from the arrangement because the cost of these services would otherwise be borne directly by us. You should consider these conflicts of interest when selecting a custodian. The products and services provided by RJA and Schwab, how they benefit us, and the related conflicts of interest are described above in Item 12. B. Compensation to Non-Supervised Persons for Client Referrals LeClair Wealth Partners seeks to enter into agreements with individuals and organizations, including Zoe, some of whom may be affiliated or unaffiliated with LeClair Wealth Partners for the referral of clients to us. All such agreements will be in writing and comply with the applicable state and federal regulations. If a client is introduced to LeClair Wealth Partners by a solicitor, LeClair Wealth Partners will pay that solicitor a fee in accordance with the applicable federal and state securities law requirements. While the specific terms of each agreement may differ, generally, the compensation will be based upon LeClair Wealth Partners’s engagement of new clients and the retention of those clients and would be calculated using a varying percentage of the fees paid to LeClair Wealth Partners by such clients until the account is closed by written authorization from the client. Any such fee shall be paid solely from LeClair Wealth Partners’s fees, and shall not result in any additional charge to the client. Each prospective client who is referred to LeClair Wealth Partners under such an arrangement will receive a copy of this Brochure and a separate written disclosure document disclosing the nature of the relationship between the third party solicitor and LeClair Wealth Partners and the compensation that will be paid by us to the third party. The solicitor is required to obtain the client’s signature acknowledging receipt of this Brochure and the solicitor’s written disclosure statement. In any case, applicable state laws may require these persons to become licensed either as representatives of LeClair Wealth Partners or as an independent investment adviser. LeClair Wealth Partners will request that our clients acknowledge this arrangement prior to acceptance of the clients’ account. Item 15 – Custody All clients must utilize a “qualified custodian” as detailed in Item 12. Clients are required to engage the custodian to retain their funds and securities and direct LeClair Wealth Partners to utilize the custodian for the client’s securities transactions. LeClair Wealth Partners’s agreement with clients and/or the clients’ separate agreements with the B/D Custodian may authorize LeClair Wealth Partners through such BD/Custodian to debit the clients’ accounts for the amount of LeClair Wealth Partners’s fee and to directly remit that fee to LeClair Wealth Partners in accordance with applicable custody rules. The BD/Custodian recommended by LeClair Wealth Partners has agreed to send a statement to the client, at least quarterly, indicating all amounts disbursed from the account including the amount of management fees paid directly to LeClair Wealth Partners. LeClair Wealth Partners encourages clients to review the official statements provided by the custodian, and to compare such statements with any reports or other 25  LeClair Wealth Partners Disclosure Brochure statements received from LeClair Wealth Partners. For more information about custodians and brokerage practices, see “Item 12 - Brokerage Practices.” Item 16 – Investment Discretion Clients have the option of providing LeClair Wealth Partners with investment discretion on their behalf, pursuant to a grant of a limited power of attorney contained in LeClair Wealth Partners’s client agreement. By granting LeClair Wealth Partners investment discretion, a client authorizes LeClair Wealth Partners to direct securities transactions and determine which securities are bought and sold, the total amount to be bought and sold, and the costs at which the transactions will be effected. Clients may impose reasonable limitations in the form of specific constraints on any of these areas of discretion with the consent and written acknowledgement of LeClair Wealth Partners if LeClair Wealth Partners determines, in its sole discretion, that the conditions would not materially impact the performance of a management strategy or prove overly burdensome for LeClair Wealth Partners. See also Item 4(C), Client-Tailored Advisory Services. Item 17 – Voting Client Securities LeClair Wealth Partners does not accept the authority to and does not vote proxies on behalf of clients. Clients retain the responsibility for receiving and voting proxies for all and any securities maintained in client portfolios. Item 18 – Financial Information LeClair Wealth Partners is not required to disclose any financial information pursuant to this item due to the following: a) LeClair Wealth Partners does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance of rendering services; b) LeClair Wealth Partners is unaware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments relating to its discretionary authority over certain client accounts; and c) LeClair Wealth Partners has never been the subject of a bankruptcy petition. 51257058.1 26 

LECLAIR WEALTH PARTNERS LLC FORM ADV PART 2A, APPENDIX 1 WRAP FEE PROGRAM BROCHURE Item 1 – Cover Page 6515 Longshore Loop, Suite 100 Dublin, Ohio 43017 888-277-5704 www.leclairwealthpartners.com This wrap fee program brochure provides information about the qualifications and business practices of LeClair Wealth Partners LLC. If you have any questions regarding the contents of this brochure, please contact our Chief Compliance Officer, Keith Dwyer by telephone at 513-977-8196 or by email at keith.dwyer@dinsmorecomplianceservices.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. LeClair Wealth Partners LLC is a registered investment adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. Additional information about LeClair Wealth Partners LLC is available on the SEC’s website at www.adviserinfo.sec.gov. February 13, 2026  LeClair Wealth Partners Wrap Fee Program Brochure Item 2 – Material Changes Form ADV Part 2A, Appendix 1 requires registered investment advisers to amend their wrap fee program brochure when information becomes materially inaccurate. If there are any material changes to an adviser’s wrap fee program disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. The following material changes occurred since the last filing on 2/5/2025: -Item 4, added the addition of flat fee investment management for certain accounts -Item 6, added additional investment management risks -Item 9, added information about certain broker dealer licensed individuals who participate in investment banking activities 2  Item 3 - Table of Contents Item 1 – Cover Page ...................................................................................................................................... 1 Item 2 – Material Changes ............................................................................................................................ 2 Item 3 - Table of Contents ............................................................................................................................ 3 Item 4 – Services, Fees and Compensation ................................................................................................... 4 Item 5 – Account Requirments and Types of Clients ................................................................................... 7 Item 6 – Portfolio Manager Selection and Evaluation .................................................................................. 8 Item 7 – Client Information Provided to Portfolio Managers ..................................................................... 16 Item 8 – Client Contact with Portfolio Managers ....................................................................................... 16 Item 9 – Additional Information ................................................................................................................. 16  LeClair Wealth Partners Wrap Fee Program Brochure Item 4 – Services, Fees and Compensation LeClair Wealth Partners LLC (“LeClair Wealth Partners”, “LeClair” or the “Firm”) is a corporation organized in the State of Ohio. LeClair Wealth Partners is an investment advisory firm registered with the United States Securities and Exchange Commission (“SEC”). LeClair Wealth Partners is owned by LeClair HoldCo LLC, a corporation organized in the State of Florida. LeClair HoldCo is owned by Steven LeClair. The LeClair Wealth Partners wrap fee program (the “LeClair Wealth Partners Wrap Fee Program”) is an investment advisory program sponsored by LeClair Wealth Partners. Investment management services are provided to clients of LeClair Wealth Partners through the LeClair Wealth Partners Wrap Fee Program. In addition to the LeClair Wealth Partners Wrap Fee Program, the Firm offers financial planning services, investment management services through non-wrap programs and investment management to certain types of qualified plan clients under different arrangements then those described in this Brochure. Information about these services is contained in the Firm’s Form ADV Part 2A. A. Description of the LeClair Wealth Partners Wrap Fee Program LeClair Wealth Partners offers investment management services on a discretionary basis and non- discretionary basis. All investment advice provided is customized to each client’s investment objectives and financial needs. The information provided by the client, together with any other information relating to the client’s overall financial circumstances, will be used by LeClair Wealth Partners to determine the appropriate portfolio asset allocation and investment strategy for the client. Financial planning services also are provided, depending on the needs of the client. LeClair Wealth Partners provides investment management services to clients through a wrap fee program (the “LeClair Wealth Partners Wrap Fee Program”). See LeClair Wealth Partners’ Form ADV Part 2A, Appendix 1 for additional information regarding the LeClair Wealth Partners Wrap Fee Program. The securities utilized by LeClair Wealth Partners in the LeClair Wealth Partners Wrap Fee Program client accounts mainly consist of registered mutual funds and exchange traded funds (ETFs), but we will also invest in equity securities, corporate bonds, REITS, variable annuities, private funds/alternative investments, closed end funds and structured notes, if we determine such investments fit within a client’s objectives and are in the best interest of our clients. LeClair Wealth Partners may further recommend to clients that all or a portion of their LeClair Wealth Partners Wrap Fee Program investment portfolio be managed on a discretionary basis by one or more unaffiliated money managers or investment platforms (“External Managers”). The client may be required to enter into a separate agreement with the External Manager(s), which will set forth the terms and conditions of the client’s engagement of the External Manager. LeClair Wealth Partners generally renders services to the client relative to the discretionary selection of External Managers. LeClair Wealth Partners also assists in establishing the client’s investment objectives for the assets managed by External Managers, monitors and reviews the account performance and defines any restrictions on the account. The investment management fees charged by the designated External Managers are exclusive of, and in addition to, the annual advisory fee charged by LeClair Wealth Partners. For External Managers made available through the B/D Custodian RJA, custody and securities transactions commissions are included within the LeClair Wealth Partners Wrap Fee Program fee. If an External Manager is utilized that engages in brokerage transactions and/or custody services with a broker-dealer/custodian other than RJA, the fees charged by 4  LeClair Wealth Partners Wrap Fee Program Brochure that broker-dealer/custodian will be exclusive of, and in addition to, the annual LeClair Wealth Partners Wrap Program fee. LeClair Wealth Partners participates in the Raymond James and Associates, Inc. (“RJA”) Ambassador Program custodial platform. LeClair Wealth Partners will recommend that LeClair Wealth Partners Wrap Fee Program clients establish brokerage accounts with RJA to maintain custody of clients’ assets and to effect trades for their accounts. RJA, member New York Stock Exchange/SIPC, is a “qualified custodian” as that term is described in Rule 206(4)-2 of the Investment Advisers Act of 1940. Note for IRA and Retirement Plan Clients: When LeClair Wealth Partners provides investment advice to you regarding your retirement plan account or individual retirement account, LeClair Wealth Partners is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way LeClair Wealth Partners makes money creates some conflicts with your interests, so LeClair Wealth Partners operates under a special rule that requires LeClair Wealth Partners to act in your best interest and not put LeClair Wealth Partners’s interest ahead of yours. Note Regarding Tax or Legal Advice: In providing services, LeClair Wealth Partners does not offer or otherwise provide tax or legal advice. LeClair Wealth Partners will, at a client’s direction and approval, work with a client’s existing tax or legal professionals to assist in the provision of the services. Fees charged by any tax, legal or other third-party professionals are the responsibility of the client. LeClair Wealth Partners may refer professionals; however, there is no compensation to LeClair Wealth Partners for these referrals, and clients are under no obligation to use the referred service providers. The LeClair Wealth Partners Wrap Fee Program Fee B. The LeClair Wealth Partners Wrap Fee Program Fee covers LeClair Wealth Partners’s advisory services, custody and commissions for securities transactions effected through RJA. The number of transactions made in clients’ accounts, the size of the accounts, and the securities used to construct a portfolio, as well as the commissions charged for each transaction, determines the relative cost of the LeClair Wealth Partners Wrap Fee Program versus paying for execution on a per transaction basis and paying a separate fee for advisory services. Participants in the LeClair Wealth Partners Wrap Fee Program may pay a higher or lower aggregate fee than if the investment management and brokerage services are purchased separately. LeClair Wealth Partners does not charge its clients higher advisory fees based on their trading activity, but clients should be aware that LeClair Wealth Partners may have an incentive to limit its trading activities in client accounts because LeClair Wealth Partners is charged for executed trades. LeClair Wealth Partners addresses this conflict of interest by this disclosure and by its policies and procedures which work to ensure that accounts are managed in accordance with clients’ goals and objectives without consideration of trading costs incurred by LeClair Wealth Partners. Cash and Margin Positions At any specific point in time, depending upon perceived or anticipated market conditions or events (there being no guarantee that such anticipated market conditions/events will occur), LeClair Wealth Partners may maintain cash positions for defensive or other purposes. All cash positions (money markets, etc.) will be included as part of assets under management for purposes of calculating the LeClair Wealth Partners Wrap Fee Program Fee. In addition, LeClair Wealth Partners does not reduce management fees for margin borrowing, regardless of whether the assets 5  LeClair Wealth Partners Wrap Fee Program Brochure are in cash or other securities. LeClair Wealth Partners has a financial incentive to recommend that clients borrow money for the purchase of additional securities for the client’s account managed by LeClair Wealth Partners or otherwise not liquidate some or all the assets LeClair Wealth Partners manages. LeClair Wealth Partners addresses this conflict of interest by this disclosure and working and working to ensure that any recommendation to a client regarding the use of margin is suitable for the client. Additional Fees and Expenses In addition to the LeClair Wealth Partners Wrap Fee Program Fee, clients will be responsible for transfer taxes, odd lot differentials, exchange fees, interest charges, ADR processing fees and any charges, taxes or other fees mandated by any federal, state or other applicable law, retirement plan account fees (where applicable), electronic fund and wire fees. Furthermore, LeClair Wealth Partners fees do not cover transaction fees or “trade away” fees imposed for trades placed away from RJA. In addition, for External Managers, clients should review each manager’s Form ADV 2A disclosure brochure and any contract they sign with the External Manager (in a dual contract relationship). The client is responsible for all such fees and expenses, as well as trading and custody costs of a broker-dealer/custodian other than RJA if utilized by that External Manager. Fee Schedule In providing investment management services pursuant to the LeClair Wealth Partners Wrap Fee Program, LeClair Wealth Partners charges an annual investment management services fee that is agreed upon with each client and set forth in an agreement executed by LeClair Wealth Partners and the client. The LeClair Wealth Partners Wrap Fee Program investment management fee is based on a percentage of the value of assets under management, or a flat fee, and is generally paid quarterly in advance. When a client’s account is opened, the LeClair Wealth Partners Wrap Fee Program investment management services fee is billed for the remainder of the current quarterly billing period and is based on the client’s initial contribution to the client account. Subsequent quarterly LeClair Wealth Fee Partners Wrap Fee Program investment management services fees will be based on the client’s account value as of the last business day of the previous calendar quarter. If cash or securities, or a combination thereof, amounting to at least $100,000 are deposited to or withdrawn from a LeClair Wealth Partners Wrap Fee Program client’s account on an individual business day in the first two months of the quarter, LeClair Wealth Partners will (i) assess investment management services fees to the deposited assets based on the value of the assets on the date of deposit for the pro rata number of days remaining in the quarter, or (ii) refund prepaid LeClair Wealth Partners Wrap Fee Program investment management services fees based on the value of the assets on the date of withdrawal for the pro rata number of days remaining in the quarter. No additional LeClair Wealth Partners Wrap Fee Program investment management services fees or adjustments to previously assessed LeClair Wealth Partners Wrap Fee Program investment management services fees will be made in connection with deposits or withdrawals that occur during the last month of the quarter. For purposes of LeClair Wealth Partners Wrap Fee Program investment management services fee calculation, LeClair Wealth Partners utilizes third party sources, such as pricing services, custodians, fund administrators, and client-provided sources. For purposes of fee calculation, the 6  LeClair Wealth Partners Wrap Fee Program Brochure asset value of LeClair Wealth Partner Wrap Fee Program client accounts include cash and cash equivalents, as well as margined securities. LeClair Wealth Partners does not reduce LeClair Wealth Partners Wrap Fee Program investment management fees for margin borrowing, regardless of whether the assets are in cash or other securities. LeClair Wealth Partners has a financial incentive to recommend that clients borrow money for the purchase of additional securities for the client’s LeClair Wealth Partners Wrap Fee Program account managed by LeClair Wealth Partners or otherwise not liquidate some or all the assets LeClair Wealth Partners manages. LeClair Wealth Partners addresses this conflict of interest by this disclosure and working to ensure that any recommendation to a client regarding the use of margin is suitable for the client. Following is the LeClair Wealth Partners Wrap Fee Program asset based fee: FEE SCHEDULE Market Value of Assets Rate Up to $1,999,999 1.50% $2,000,000 to $4,999,999 1.25% $5,000,000 to $9,999,999 1.00% $10,000,000 to $24,999,999 0.75% $25,000,000 to $49,999,999 0.50% $50,000,000 to $99,999,999 0.35% $100,000,000 and above 0.25% The percentage for the highest range of Managed Asset value achieved applies to all Managed Assets, not just Managed Assets within that range. There are clients of LeClair Wealth Partners who were clients of an unaffiliated investment adviser at which current LeClair Wealth Partners personnel served as investment adviser representatives that pay a higher fee for investment management services. LeClair Wealth Partners also began offering flat fee investment management which is detailed in an individual’s contract. LeClair Wealth Partners’s policy is to include all related client accounts, specifically the accounts of direct family members sharing the same residence address, for purposes of determining a client’s market value of assets. Compensation for Recommending the LeClair Wealth Partners Wrap Fee Program C. LeClair Wealth Partners does not have any arrangements where it receives an economic benefit from a third party for recommending the LeClair Wealth Partners Wrap Fee Program. Item 5 – Account Requirements and Types of Clients Investment management services through the LeClair Wealth Partners Wrap Fee Program are provided to individuals, including high net worth individuals, families, family offices, trusts, businesses, charitable foundations, and retirement/profit-sharing plans. LeClair Wealth Partners does not impose a minimum portfolio size or a minimum initial investment to open a LeClair Wealth Partners Wrap Fee Program 7  LeClair Wealth Partners Wrap Fee Program Brochure account. However, LeClair Wealth Partners does reserve the right to accept or decline a potential client for any reason in its sole discretion. Item 6 – Portfolio Manager Selection and Evaluation The LeClair Wealth Partners Wrap Fee Program utilize advisers, the External Managers, in addition to LeClair Wealth Partners. RJA provides access to External Managers that have been subject to initial and ongoing due diligence and reviews by RJA. In making External Managers available RJA evaluates External Managers’ investment philosophy and policies, records as an investment adviser, and the investment disciplines or strategies the External Manager is able to offer. In addition, in determining whether to continue to make an External Manager available RJA conducts ongoing reviews of performance calculations, peer comparisons, and examination of portfolio characteristics and holdings. This RJA External Manager information is made available to, and reviewed by, LeClair Wealth Partners. Performance information provided by External Managers is compared by RJA to publicly available resources for reasonableness. External Manager provided performance information is not independently verified by RJA nor LeClair Wealth Partners. Advisory Services Offered by LeClair Wealth Partners A. See Item 4 of this Wrap Fee LeClair Wealth Partners Wrap Fee Program Brochure for a full description of the LeClair Wealth Partners Wrap Fee Program. In addition to the LeClair Wealth Partners Wrap Fee Program, LeClair Wealth Partners provides investment management on a non-wrap fee basis to certain clients, retirement plan clients and financial planning and consulting services. Investment Management Services to Retirement Plans LeClair Wealth Partners offers discretionary and non-discretionary advisory services to qualified plans, including 401k plans. These services include, depending upon the needs of the plan client, recommending, or for discretionary clients selecting, investment options for plans to offer to participants, ongoing monitoring of a plan’s investment options, assisting plan fiduciaries in creating and/or updating the plan’s written investment policy statements, working with plan service providers, and providing general investment education to plan participants. Financial Planning Services and Consulting Services LeClair Wealth Partners offers personal comprehensive financial planning services to set forth goals, objectives and implementation strategies for the client over the long-term. Depending upon individual client requirements, the comprehensive financial plan will include recommendations for retirement planning, educational planning, estate planning, cash flow planning, long term health care planning, tax planning and insurance needs and analysis. LeClair Wealth Partners prepares and provides the financial planning client with a written comprehensive financial plan and performs periodic reviews of the plan with the client, as agreed upon with the client. In addition, LeClair Wealth Partners provides financial planning services that are completed upon the delivery of the financial plan to the client. Clients should notify us promptly anytime there is a change in their financial situation, goals, objectives, or needs and/or if there is any change to the financial information initially provided to us. B. Client Tailored Advisory Services 8  LeClair Wealth Partners Wrap Fee Program Brochure Clients may impose reasonable restrictions on the management of their accounts if LeClair Wealth Partners determines, in its sole discretion, that the conditions would not materially impact the performance of a management strategy or prove overly burdensome for LeClair Wealth Partners’s management efforts. The LeClair Wealth Partners Wrap Fee Program C. As described above, LeClair Wealth Partners is one of the portfolio managers of the LeClair Wealth Partners Wrap Fee Program. See Item 4 above for a description of the LeClair Wealth Partners Wrap Fee Program and the other advisory services offered by LeClair Wealth Partners. Clients may impose reasonable restrictions on the management of their accounts if LeClair Wealth Partners determines, in its sole discretion, that the conditions would not materially impact the performance of a management strategy or prove overly burdensome for LeClair Wealth Partners’s management efforts. As a portfolio manager, LeClair Wealth Partners receives the LeClair Wealth Partners Wrap Fee Program Fee after the payment of the brokerage, execution and custodian fees and expenses. Performance-Based Fees and Side-By-Side Management D. LeClair Wealth Partners does not charge performance-based fees or participate in side-by-side management. Performance-based fees are fees that are based on a share of capital gains or capital appreciation of a client’s account. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. LeClair Wealth Partners’s fees are calculated as described in Item 5 above. E. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategies A primary step in LeClair Wealth Partners’s investment strategy is getting to know the clients – to understand their financial condition, risk profile, investment goals, tax situation, liquidity constraints – and assemble a complete picture of their financial situation. To aid in this understanding, LeClair Wealth Partners offers clients financial planning that is highly customized and tailored. This comprehensive approach is integral to the way that LeClair Wealth Partners does business. Once LeClair Wealth Partners has a true understanding of its clients’ needs and goals, the investment process can begin, and the Firm can recommend strategies and investments that it believes are aligned with the client’s goals and risk profile. LeClair Wealth Partners primarily employs fundamental analysis methods in developing investment strategies for its clients. Research and analysis from LeClair Wealth Partners is based on numerous sources, including third-party research materials and publicly-available materials, such as company annual reports, prospectuses, and press releases. LeClair Wealth Partners generally employs a long-term investment strategy for its clients, as consistent with their financial goals. At times, the Firm may also buy and sell positions that are more short-term in nature, depending on the goals of the client and/or the fundamentals of the security, sector or asset class. Client portfolios with similar investment objectives and asset allocation goals may own different securities and investments. The client’s portfolio size, tax sensitivity, desire for simplicity, income needs, long-term wealth transfer objectives, time horizon and choice of custodian are all factors that influence LeClair Wealth Partners’s investment recommendations. 9  LeClair Wealth Partners Wrap Fee Program Brochure Investing in securities involves a risk of loss. A client can lose all or a substantial portion of his/her investment. A client should be willing to bear such a loss. Some investments are intended only for sophisticated investors and can involve a high degree of risk. Material Risks Involved Investing in securities involves a significant risk of loss which clients should be prepared to bear. LeClair Wealth Partners’s investment recommendations are subject to various market, currency, economic, political and business risks, and such investment decisions will not always be profitable. Clients should be aware that there may be a loss or depreciation to the value of the client’s account. There can be no assurance that the client’s investment objectives will be obtained and no inference to the contrary should be made. Generally, the market value of equity stocks will fluctuate with market conditions, and small-stock prices generally will fluctuate more than large-stock prices. The market value of fixed income securities will generally fluctuate inversely with interest rates and other market conditions prior to maturity. Fixed income securities are obligations of the issuer to make payments of principal and/or interest on future dates, and include, among other securities: bonds, notes and debentures issued by corporations; debt securities issued or guaranteed by the U.S. government or one of its agencies or instrumentalities, or by a non-U.S. government or one of its agencies or instrumentalities; municipal securities; and mortgage-backed and asset-backed securities. These securities may pay fixed, variable, or floating rates of interest, and may include zero coupon obligations and inflation-linked fixed income securities. The value of longer duration fixed income securities will generally fluctuate more than shorter duration fixed income securities. Investments in overseas markets also pose special risks, including currency fluctuation and political risks, and it may be more volatile than that of a U.S. only investment. Such risks are generally intensified for investments in emerging markets. In addition, there is no assurance that a mutual fund or ETF will achieve its investment objective. Past performance of investments is no guarantee of future results. Additional risks involved in the securities recommended by LeClair Wealth Partners include, among others: • Stock market risk, which is the chance that stock prices overall will decline. The market value of equity securities will generally fluctuate with market conditions. Stock markets tend to move in cycles, with periods of rising prices and periods of falling prices. Prices of equity securities tend to fluctuate over the short term as a result of factors affecting the individual companies, industries or the securities market as a whole. Equity securities generally have greater price volatility than fixed income securities. • • Sector risk, which is the chance that significant problems will affect a particular sector, or that returns from that sector will trail returns from the overall stock market. Daily fluctuations in specific market sectors are often more extreme than fluctuations in the overall market. Issuer risk, which is the risk that the value of a security will decline for reasons directly related to the issuer, such as management performance, financial leverage, and reduced demand for the issuer's goods or services. • Non-diversification risk, which is the risk of focusing investments in a small number of issuers, industries or foreign currencies, including being more susceptible to risks 10  LeClair Wealth Partners Wrap Fee Program Brochure associated with a single economic, political or regulatory occurrence than a more diversified portfolio might be. • Value investing risk, which is the risk that value stocks not increase in price, not issue the anticipated stock dividends, or decline in price, either because the market fails to recognize the stock’s intrinsic value, or because the expected value was misgauged. If the market does not recognize that the securities are undervalued, the prices of those securities might not appreciate as anticipated. They also may decline in price even though in theory they are already undervalued. Value stocks are typically less volatile than growth stocks, but may lag behind growth stocks in an up market. • Smaller company risk, which is the risk that the value of securities issued by a smaller company will go up or down, sometimes rapidly and unpredictably as compared to more widely held securities. Investments in smaller companies are subject to greater levels of credit, market and issuer risk. • • Foreign (non-U.S.) investment risk, which is the risk that investing in foreign securities result in the portfolio experiencing more rapid and extreme changes in value than a portfolio that invests exclusively in securities of U.S. companies. Risks associated with investing in foreign securities include fluctuations in the exchange rates of foreign currencies that may affect the U.S. dollar value of a security, the possibility of substantial price volatility as a result of political and economic instability in the foreign country, less public information about issuers of securities, different securities regulation, different accounting, auditing and financial reporting standards and less liquidity than in the U.S. markets. Interest rate risk, which is the chance that prices of fixed income securities decline because of rising interest rates. Similarly, the income from fixed income securities may decline because of falling interest rates. • Credit risk, which is the chance that an issuer of a fixed income security will fail to pay interest and principal in a timely manner, or that negative perceptions of the issuer’s ability to make such payments will cause the price of that fixed income security to decline. • Exchange Traded Fund (ETF) risk, which is the risk of an investment in an ETF, including the possible loss of principal. ETFs typically trade on a securities exchange and the prices of their shares fluctuate throughout the day based on supply and demand, which may not correlate to their net asset values. Although ETF shares will be listed on an exchange, there can be no guarantee that an active trading market will develop or continue. Owning an ETF generally reflects the risks of owning the underlying securities it is designed to track. ETFs are also subject to secondary market trading risks. In addition, an ETF may not replicate exactly the performance of the index it seeks to track for a number of reasons, including transaction costs incurred by the ETF, the temporary unavailability of certain securities in the secondary market, or discrepancies between the ETF and the index with respect to weighting of securities or number of securities held.  Derivatives Risk, entails the use of derivative instruments for a variety of purposes, including hedging, risk management, portfolio management or to earn income. A derivative is a financial instrument whose value is based, in part, on the value of an underlying asset, interest rate, index or financial instrument (“reference instrument” or “underlying asset”). In this context, derivatives include but are not limited to futures, forwards, options, participatory notes, warrants, swaps and other similar instruments that are normally valued based upon another or related asset. The use of 11  LeClair Wealth Partners Wrap Fee Program Brochure derivatives can lead to losses because of adverse movements in the price or value of the reference instrument, failure of the counterparty or tax or regulatory constraints. Prevailing interest rates and volatility levels, among other things, also affect the value of derivative instruments. A derivative instrument often has risks similar to its underlying asset and can have additional risks, including imperfect correlation between the value of the derivative and the underlying asset, risks of default by the counterparty to certain transactions, magnification of losses incurred due to changes in the market value of the securities, instruments, indices or interest rates to which the derivative instrument relates, risks that the transactions might not be liquid and risks arising from margin requirements. The use of derivatives involves risks that are different from, and possibly greater than, the risks associated with other portfolio investments. Derivatives can involve the use of highly specialized instruments that require investment techniques and risk analyses different from those associated with other portfolio investments. Certain derivative transactions give rise to a form of leverage, which magnifies the portfolio’s exposure to the underlying asset. Leverage associated with derivative transactions could cause an account to liquidate portfolio positions when it might not be advantageous to do so to satisfy its obligations or to meet earmarking or segregation requirements, including with respect to certain funds to comply with applicable SEC rules and regulations, or could cause an account’s value to be more volatile than might have been the case absent such leverage. Derivatives risk could be more significant when derivatives are used to enhance return or as a substitute for a position or security, rather than solely to hedge the risk of a position or security held by a client portfolio. Derivatives for hedging purposes might not reduce risk if they are not sufficiently correlated to the position being hedged. A decision as to whether, when and how to use derivatives involves the exercise of specialized skill and judgment, and a transaction could be unsuccessful in whole or in part because of market behavior or unexpected events. Derivative instruments can be difficult to value, can be illiquid, and can be subject to wide swings in valuation caused by changes in the value of the underlying instrument. If a derivative counterparty is unable to honor its commitments, the value of a client portfolio could decline and/or the portfolio could experience delays in the return of collateral or other assets held by the counterparty. The loss on derivative transactions can substantially exceed the initial investment. Certain strategies use derivatives extensively. Derivative investments also involve the risks relating to the reference instrument. Although certain strategies seek to use derivatives to further a client’s investment objectives, there is no assurance that the use of derivatives will achieve this result.  Hedging Strategy risks, entails engaging in transactions designed to reduce the risk or to protect the value of investments, including securities and currency hedging transactions. These hedging strategies could involve a variety of derivative transactions, including transactions in forward, swap and option contracts or other financial instruments with similar characteristics, including, without limitation, forward foreign currency exchange contracts, currency and interest rate swaps, options and short sales (collectively “Hedging Instruments”). Certain risks associated with Hedging Instruments are further detailed under “Derivative Risks.” Hedging against a decline in the value of a portfolio position does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of those positions decline, but establishes other positions designed to gain from those same developments, thus offsetting the decline in the portfolio positions’ value. While these transactions can reduce the risks associated with an investment, the transactions themselves entail risks that are different from and possibly greater than, the risks 12  LeClair Wealth Partners Wrap Fee Program Brochure associated with other portfolio investments. The use of Hedging Instruments could require investment techniques and risks analyses different from those associated with other portfolio investments. The risks posed by these transactions include, but are not limited to, interest rate risk, market risk, the risk that these complex instruments and techniques will not be successfully evaluated, monitored or priced, the risk that counterparties will default on their obligations, liquidity risk and leverage risk. Changes in liquidity can result in significant, rapid and unpredictable changes in the prices for derivatives. Thus, while the accounts might benefit from the use of Hedging Instruments, unanticipated changes in interest rates, securities prices or currency exchange rates could result in a poorer overall performance for the accounts than if they had not used such Hedging Instruments.  Artificial Intelligence risk. Artificial Intelligence is a branch of computer science focused on creating systems capable of performing taks that typically require human intelligence; this includes, among other things, methods for analyzing, modeling and understanding language as well as developing algorithms that can learn to perform various tasks. Such usage is subject to the limitations of design of the application and the sourcing of data. The use of artificial intelligence has inherent risks such as the reliance on accurate imputs, sourcing and interpretation of data, and human interpretation of results. Artificial intelligence continues to develop rapidly and it’s impossible to predict future risk that may arise from such development. • Management risk, which is the risk that the investment techniques and risk analyses applied by LeClair Wealth Partners may not produce the desired results and that legislative, regulatory, or tax developments, affect the investment techniques available to LeClair Wealth Partners. There is no guarantee that a client’s investment objectives will be achieved. • • Real Estate risk, which is the risk that an investor’s investments in Real Estate Investment Trusts (“REITs”) or real estate-linked derivative instruments will subject the investor to risks similar to those associated with direct ownership of real estate, including losses from casualty or condemnation, and changes in local and general economic conditions, supply and demand, interest rates, zoning laws, regulatory limitations on rents, property taxes and operating expenses. An investment in REITs or real estate-linked derivative instruments subject the investor to management and tax risks. Investment Companies (“Mutual Funds”) risk, when an investor invests in mutual funds, the investor will bear additional expenses based on his/her pro rata share of the mutual fund’s operating expenses, including the management fees. The risk of owning a mutual fund generally reflects the risks of owning the underlying investments the mutual fund holds. • Cybersecurity risk, which is the risk related to unauthorized access to the systems and networks of LeClair Wealth Partners and its service providers. The computer systems, networks and devices used by LeClair Wealth Partners and service providers to us and our clients to carry out routine business operations employ a variety of protections designed to prevent damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches. Despite the various protections utilized, systems, networks or devices potentially can be breached. A client could be negatively impacted as a result of a cybersecurity breach. Cybersecurity breaches can include unauthorized access to systems, networks or devices; infection from computer viruses or other malicious software code; and attacks that shut down, disable, slow or otherwise disrupt operations, business processes or website access 13  LeClair Wealth Partners Wrap Fee Program Brochure or functionality. Cybersecurity breaches cause disruptions and impact business operations, potentially resulting in financial losses to a client; impediments to trading; the inability by us and other service providers to transact business; violations of applicable privacy and other laws; regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or other compliance costs; as well as the inadvertent release of confidential information. Similar adverse consequences could result from cybersecurity breaches affecting issues of securities in which a client invests; governmental and other regulatory authorities; exchange and other financial market operators, banks, brokers, dealers and other financial institutions; and other parties. In addition, substantial costs may be incurred by those entities in order to prevent any cybersecurity breaches in the future.  Alternative Investments / Private Funds risk, investing in alternative investments is speculative, not suitable for all clients, and intended for experienced and sophisticated investors who are willing to bear the high economic risks of the investment, which can include:          loss of all or a substantial portion of the investment due to leveraging, short-selling or other speculative investment practices; lack of liquidity in that there may be no secondary market for the investment and none expected to develop; volatility of returns; restrictions on transferring interests in the investment; potential lack of diversification and resulting higher risk due to concentration of trading authority when a single adviser is utilized; absence of information regarding valuations and pricing; delays in tax reporting; less regulation and higher fees than mutual funds; risks associated with the operations, personnel, and processes of the manager of the funds investing in alternative investments. • Closed-End Funds risk, Closed-end funds typically use a high degree of leverage. They • may be diversified or non-diversified. Risks associated with closed-end fund investments include liquidity risk, credit risk, volatility and the risk of magnified losses resulting from the use of leverage. Additionally, closed-end funds may trade below their net asset value. Structured Notes risk - • Complexity. Structured notes are complex financial instruments. Clients should understand the reference asset(s) or index(es) and determine how the note’s payoff structure incorporates such reference asset(s) or index(es) in calculating the note’s performance. This payoff calculation may include leverage multiplied on the performance of the reference asset or index, protection from losses should the reference asset or index produce negative returns, and fees. Structured notes may have complicated payoff structures that can make it difficult for clients to accurately assess their value, risk and potential for growth through the term of the structured note. Determining the performance of each note can be complex and this calculation can vary significantly from note to note depending on the structure. Notes can be structured in a wide variety of ways. Payoff structures can be leveraged, inverse, or inverse-leveraged, which may result in larger returns or losses. Clients should carefully read the prospectus for a structured 14  LeClair Wealth Partners Wrap Fee Program Brochure note to fully understand how the payoff on a note will be calculated and discuss these issues with LeClair Wealth Partners. • • Market risk. Some structured notes provide for the repayment of principal at maturity, which is often referred to as “principal protection.” This principal protection is subject to the credit risk of the issuing financial institution. Many structured notes do not offer this feature. For structured notes that do not offer principal protection, the performance of the linked asset or index may cause clients to lose some, or all, of their principal. Depending on the nature of the linked asset or index, the market risk of the structured note may include changes in equity or commodity prices, changes in interest rates or foreign exchange rates, and/or market volatility. Issuance price and note value. The price of a structured note at issuance will likely be higher than the fair value of the structured note on the date of issuance. Issuers now generally disclose an estimated value of the structured note on the cover page of the offering prospectus, allowing investors to gauge the difference between the issuer’s estimated value of the note and the issuance price. The estimated value of the notes is likely lower than the issuance price of the note to investors because issuers include the costs for selling, structuring and/or hedging the exposure on the note in the initial price of their notes. After issuance, structured notes may not be re-sold on a daily basis and thus may be difficult to value given their complexity. • Liquidity. The ability to trade or sell structured notes in a secondary market is often very limited, as structured notes (other than exchange-traded notes known as ETNs) are not listed for trading on securities exchanges. As a result, the only potential buyer for a structured note may be the issuing financial institution’s broker-dealer affiliate or the broker-dealer distributor of the structured note. In addition, issuers often specifically disclaim their intention to repurchase or make markets in the notes they issue. Clients should, therefore, be prepared to hold a structured note to its maturity date, or risk selling the note at a discount to its value at the time of sale. • Credit risk. Structured notes are unsecured debt obligations of the issuer, meaning that the issuer is obligated to make payments on the notes as promised. These promises, including any principal protection, are only as good as the financial health of the structured note issuer. If the structured note issuer defaults on these obligations, investors may lose some, or all, of the principal amount they invested in the structured notes as well as any other payments that may be due on the structured notes. There also are risks surrounding various insurance products that are recommended to LeClair Wealth Partners clients from time to time. Such risks include, but are not limited to loss of premiums. Prior to purchasing any insurance product, clients should carefully read the policy and applicable disclosure documents. Clients are advised that they should only commit assets for management that can be invested for the long term, that volatility from investing can occur, and that all investing is subject to risk. LeClair Wealth 15  LeClair Wealth Partners Wrap Fee Program Brochure Partners does not guarantee the future performance of a client’s portfolio, as investing in securities involves the risk of loss that clients should be prepared to bear. Past performance of a security or a fund is not necessarily indicative of future performance or risk of loss. Voting Client Securities F. LeClair Wealth Partners does not accept the authority to and does not vote proxies on behalf of clients. Clients retain the responsibility for receiving and voting proxies for all and any securities maintained in client LeClair Wealth Partners Wrap Fee Program portfolios. Item 7 – Client Information Provided to Portfolio Managers Any utilized External Managers for a client are selected by LeClair Wealth Partners. External Managers are not provided client information since LeClair Wealth Partners has the responsibility to determine whether the utilization of an External Manager is suitable for a client. External Managers have access to client portfolio information in their execution of advisory services for a client. Item 8 – Client Contact with Portfolio Managers Clients may contact LeClair Wealth Partners personnel during regular business hours to discuss the LeClair Wealth Partners Wrap Fee Program and their LeClair Wealth Partners Wrap Fee Program accounts. Therefore, no restrictions are placed on a client’s ability to contact or consult with LeClair Wealth Partners. Clients are not permitted access to contact or consult with any utilized External Managers. Item 9 – Additional Information Disciplinary Information A. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client’s evaluation of the adviser and the integrity of the adviser’s management. LeClair Wealth Partners has no information applicable to this Item. B. Other Financial Industry Activities and Affiliations Insurance Agent Activities Advisory persons of LeClair Wealth Partners are licensed as insurance professionals. Such persons earn commission-based compensation for selling insurance products to clients. Insurance commissions earned by advisory persons who are insurance professionals are separate from and in addition to LeClair Wealth Partners’s advisory fee. This practice presents a conflict of interest as an advisory person who is an insurance professional has an incentive to recommend insurance products for the purpose of generating commissions rather than solely based on client needs. LeClair Wealth Partners addresses this conflict through disclosure and strives to make recommendations which are in the best interests of its clients. Clients are under no obligation to purchase insurance products through any person affiliated with LeClair Wealth Partners. LeClair Wealth Partners clients should understand that lower fees and/or commissions for comparable services may be available from other insurance providers. 16  LeClair Wealth Partners Wrap Fee Program Brochure Broker Dealer Activities Certain advisory persons of LeClair Wealth Partners are licensed as broker dealer representatives. Such persons earn commission-based compensation for broker dealer transactions. Commissions earned by advisory persons are separate from and in addition to LeClair Wealth Partners’s advisory fee. These individuals are licensed through their affiliate, LeClair Capital Partners, whos primary business is investment banking. This practice presents a conflict of interest as an advisory person who participates in investment banking have an incentive to recommend LeClair Wealth Partners for asset management services. LeClair Wealth Partners addresses this conflict through disclosure and strives to make recommendations which are in the best interests of its clients. Clients are under no obligation to purchase any products through any person affiliated with LeClair Wealth Partners. LeClair Wealth Partners clients should understand that lower fees and/or commissions for comparable services may be available from other providers. C. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading LeClair Wealth Partners has a Code of Ethics (the “Code”) which requires LeClair Wealth Partners’s employees (“supervised persons”) to comply with their legal obligations and fulfill the fiduciary duties owed to the Firm’s clients. Among other things, the Code of Ethics sets forth policies and procedures related to conflicts of interest, outside business activities, gifts and entertainment, compliance with insider trading laws and policies and procedures governing personal securities trading by supervised persons. Personal securities transactions of supervised persons present potential conflicts of interest with the price obtained in client securities transactions or the investment opportunity available to clients. The Code addresses these potential conflicts by prohibiting securities trades that would breach a fiduciary duty to a client and requiring, with certain exceptions, supervised persons to report their personal securities holdings and transactions to LeClair Wealth Partners for review by the Firm’s Chief Compliance Officer. The Code also requires supervised persons to obtain pre-approval of certain investments, including initial public offerings and limited offerings. LeClair Wealth Partners will provide a copy of the Code of Ethics to any client or prospective client upon request. Review of Accounts D. While LeClair Wealth Partners Wrap Fee Program accounts are monitored on an ongoing basis, LeClair Wealth Partners’s investment adviser representatives seek to have at least one annual meeting with each client to conduct a formal review of the clients’ accounts. For smaller asset size client accounts and/or clients with less complicated financial sitations annual reviews may be done through various electronic or other means. Accounts are reviewed for consistency with the investment strategy and other parameters set forth for the account and to determine if any adjustments need to be made. Other Reviews and Triggering Factors In addition to the periodic reviews described above, reviews may be triggered by changes in an account holder’s personal, tax or financial status. Other events that may trigger a review of an account are material changes in market conditions as well as macroeconomic and company- specific 17  LeClair Wealth Partners Wrap Fee Program Brochure events. Clients are encouraged to notify LeClair Wealth Partners of any changes in his/her personal financial situation that might affect his/her investment needs, objectives, or time horizon. Regular Reports Written brokerage statements are generated no less than quarterly and are sent directly from the qualified custodian. These reports list the account positions, activity in the account over the covered period, and other related information. Clients are also sent confirmations following each brokerage account transaction unless confirmations have been waived. LeClair Wealth Partners may also determine to provide account statements and other reporting to clients on a periodic basis. Clients are urged to carefully review all custodial account statements and compare them to any statements and reports provided by LeClair Wealth Partners. LeClair Wealth Partners statements and reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. E. Client Referrals and Other Compensation Client Referrals LeClair Wealth Partners does not receive benefits from third parties for providing investment advice to clients. In addition, LeClair Wealth Partners does not enter into agreements with individuals or organizations for the referral of clients to them. LeClair Wealth Partners enters into agreements with individuals and organizations, some of whom may be affiliated or unaffiliated with LeClair Wealth Parnter for the referral of clients to us. All such agreements will be in writing and comply with the applicable state and federal regulations. Other Compensation As described above, LeClair Wealth Partners requires that LeClair Wealth Partners Wrap Fee Program clients utilize RJA as the custodian for their LeClair Wealth Partners Wrap Fee Program account(s). While there is no direct link between the investment advice LeClair Wealth Partners provides and participation in the RJA program, LeClair Wealth Partners management receives certain economic benefits from the RJA program. These benefits may include software and other technology that provides access to client account data (such as trade confirmations and account statements), facilitates trade execution (and allocation of aggregated orders for multiple client accounts), provides research, pricing information and other market data, facilitates the payment of LeClair Wealth Partners’s fees from its clients’ accounts, and assists with back-office functions, recordkeeping and client reporting. Many of these services may be used to service all or a substantial number of LeClair Wealth Partners’s accounts, including accounts not held at RJA. RJA may also make available to LeClair Wealth Partners other services intended to help LeClair Wealth Partners manage and further develop its business. These services may include consulting, publications and conferences on practice management, information technology, business succession, and marketing. In addition, RJA may make available, arrange and/or pay for these types of services to be rendered to LeClair Wealth Partners by independent third parties. RJA may discount or waive fees it would otherwise charge for some of these services, pay all or a part of the fees of a third-party providing these services to LeClair Wealth Partners, and/or RJA may pay for travel expenses relating to participation in such training. Finally, participation in the RJA program provides LeClair Wealth Partners with access to mutual funds which normally require 18  LeClair Wealth Partners Wrap Fee Program Brochure significantly higher minimum initial investments or are normally available only to institutional investors. The benefits received through participation in the RJA program do not necessarily depend upon the proportion of transactions directed to RJA. The benefits are received by LeClair Wealth Partners, in part because of commission revenue generated for RJA by LeClair Wealth Partners’s clients. This means that the investment activity in client accounts is beneficial to LeClair Wealth Partners, because RJA does not assess a fee to LeClair Wealth Partners for these services. This creates an incentive for LeClair Wealth Partners to continue to recommend RJA to its clients. While it may be possible to obtain similar custodial, execution and other services elsewhere at a lower cost, LeClair Wealth Partners believes that RJA provides an excellent combination of these services. These services are not soft dollar arrangements, but are part of the institutional platform offered by RJA. Financial Information F. LeClair Wealth Partners is not required to disclose any financial information pursuant to this item due to the following: a) LeClair Wealth Partners does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance of rendering services; b) LeClair Wealth Partners is unaware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments relating to its discretionary authority over certain client accounts; and c) LeClair Wealth Partners has never been the subject of a bankruptcy petition. 19