Liberty One Wealth Advisors

Item 1: Cover Sheet FORM ADV PART 2A INFORMATIONAL BROCHURE LIBERTY ONE WEALTH ADVISORS 2001 Market St, Suite 2500 Philadelphia, PA 19103 www.libertyonewealth.com Guilian DiLeonardo 215-776-4918 July 1, 2026 This brochure provides information about the qualifications and business practices of Liberty One Wealth Advisors. If you have any questions about the contents of this brochure, please contact us at 215-776-4918 or via email at gdileonardo@libertyonewealth.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. Liberty One Wealth Advisors is registered as an Investment Adviser with the Securities and Exchange Commission. Our registration does not imply a certain level of skill or training. Additional information about Liberty One Wealth Advisors is also available on the SEC’s website at www.adviserinfo.sec.gov.  Item 2: Statement of Material Changes In this Item, Liberty One Wealth Advisors is required to discuss any material changes that have been made to the brochure since the last annual updating amendment. Since the last filing, there have been no material changes.  Item 3: Table of Contents TABLE OF CONTENTS Item 1: Cover Sheet 1 Item 2: Statement of Material Changes 2 Item 3: Table of Contents 3 Item 4: Advisory Business 4 Item 5: Fees and Compensation 5 Item 6: Performance-Based Fees 7 Item 7: Types of Clients 7 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss 7 Item 9: Disciplinary Information 10 Item 10: Other Financial Industry Activities and Affiliations 10 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 11 Item 12: Brokerage Practices 11 Item 13: Review of Accounts 12 Item 14: Client Referrals and Other Compensation 12 Item 15: Custody 13 Item 16: Investment Discretion 13 Item 17: Voting Client Securities 14 Item 18: Financial Information 14 Wrap Fee Program Brochure 15 ADV Part 2B: Guilian DiLeonardo i ADV Part 2B: Jacky Petit-Homme ii ADV Part 2B: Fan Feng iii vi ADV Part 2B: Christopher Klein v ADV Part 2B: Paul Zablotney Privacy Notice  INFORMATIONAL BROCHURE LIBERTY ONE WEALTH ADVISORS Item 4: Advisory Business Liberty One Wealth Advisors (“LOWA”) was formed in June, 2021. LOWA is owned by Liberty One Holdings, Inc., which is owned by Guilian DiLeonardo, Jacky Petit-Homme, and Fan Feng. As of December 31, 2025, LOWA has approximately $178,357,037 in assets under management over 832 accounts, all of which are managed on a discretionary basis. Financial Planning Services LOWA is first and foremost a financial planning firm. LOWA develops financial plans for its clients and uses those plans to make the appropriate investments on their behalf to drive success in their financial life. The process begins with a goals-based approach. The first step is laying out the client’s goal(s) for their financial life. From there LOWA reviews the totality of a client’s financial circumstances, which include assets, liabilities, and overall cash flow. Since LOWA believes that the biggest determinant of success in a client’s plan is the client’s spending, there will be an in-depth discussion on their current expenses and their future spending plan. Clients may impose restrictions on investing in certain securities or types of securities. From this client-provided information, LOWA evaluates the client’s current positioning to ensure they can make the best recommendations based on these life factors. Coupled with conversations about what the client is looking to achieve and the degree of risk they are willing to take, LOWA develops the optimal strategy for accomplishing the client’s goals, with the ultimate goal of allowing the client to live their life financially independent. The financial plan provided will lay out the strategies and overall potential success of the client’s investment life. Investment Advisory Services LOWA tailors its advisory services to the individual needs of this client. Services are selected based on the financial plan generated for the client and the personal discussions described above. LOWA builds out an investment allocation portfolio driven by the goals and needs of the client. The client's personal investment plan contains an asset allocation target of which LOWA creates and manages a portfolio based on that plan and allocation targets. LOWA provides continuous advice to clients regarding the investment of their funds based on the individual needs of the client. Wrap Program LOWA recommends that investment accounts be held in custody by Schwab Advisor Services (“Schwab”), member FINRA/SIPC, an unaffiliated SEC-registered broker-dealer and FINRA member. Schwab offers enhanced services to independent investment advisors. These services include custody of securities, trade execution platforms, and access to research not available to the general public. Schwab is wholly independent from LOWA. It is expected that most, if not all, transactions in a given client account will be cleared through the custodian of that account in its capacity as a broker-dealer. For some clients, LOWA may include certain transactional costs in the client’s management fee. This arrangement is referred to as a “Wrap Program”. For accounts in the Wrap Program, LOWA pays a fee to the account custodian based on the total amount of client assets enrolled in the Wrap Program,  thus taking on many of the clients’ transactions cost. Fees included in the wrap fee include transaction fees for the purchase or sale of securities, but do not include expenses related to the use of margin, wire transfer fees, the fees charged to shareholders of mutual funds or ETFs, mark-ups and mark- downs, spreads, odd-lot differentials, fees charged by regulatory agencies, and any transaction fees for securities trades executed by a broker-dealer other than the primary custodian. Expenses for the management fees of third-party managers are also not included in the Wrap Program, and to the extent utilized, you will be responsible for such fees. There is no difference between how LOWA manages wrap fee accounts and how LOWA manages other accounts. Because of the nature of a wrap fee program, where wrap fees are not tied to an account’s frequency of trading and apply to generally all assets in the account, the wrap fee program client may pay more or less than if the client had compensated LOWA outside of the wrap fee program. For example, if a client’s account is rarely traded, the transaction fees the client would have paid would be minimal, thus limiting the benefits of “wrapping” management fees and transaction fees. Clients whose accounts will rarely be traded should carefully consider whether the Wrap Program is appropriate. Clients are not required to participate in the Wrap Program. The benefits under a wrap fee program depend, in part, upon the size of the account, the costs associated with managing the account, and the frequency or type of securities transactions executed in the account. For example, a wrap fee program may not be suitable for all accounts, including but not limited to accounts holding primarily, and for any substantial period of time, cash or cash equivalent investments, fixed income securities or no- transaction-fee mutual funds, or any other type of security that can be traded without commissions or other transaction fees. In order to evaluate whether a wrap [or bundled] fee arrangement is appropriate for you, you should compare the agreed-upon Wrap Program Fee and any other costs associated with participating in our Wrap Fee Program with the amounts that would be charged by other advisers, broker-dealers, and custodians, for advisory fees, brokerage and execution costs, and custodial services comparable to those provided under the Wrap Fee Program. ETFs. LOWA is the sole portfolio manager in the wrap program, which means that LOWA receives a portion of the wrap fee for our services. Transaction fees are paid to various broker-dealers, mutual funds, and The remainder of the wrap fee is the management fee payable to LOWA. As discussed more fully in the wrap brochure, the transaction fees paid to the account custodian are based on a rate per trade that is negotiated between LOWA and the custodian clearing the trades. LOWA will receive no additional compensation for offering the wrap fee program. Clients whose assets are invested through the LOWA Wrap Program should please see the separate Wrap Fee Brochure for a more complete description of the Wrap Program. Participant Account Management (Discretionary) LOWA has contracted with a third-party platform, Pontera, to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows LOWA to avoid being considered to have custody of Client funds since there is no direct access to Client log-in credentials to affect trades. LOWA is not affiliated with the platform in any way and receives no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, LOWA will review the current account allocations. When deemed necessary, LOWA will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary.  Insurance Consulting with a Third-Party Upon review of an investor's financial status, LOWA may propose that Clients include, as part of his or her financial portfolio, one or more types of products that are not part of the investment advisory services provided by LOWA, such as insurance products. If Clients choose to include such a product in his or her financial portfolio, LOWA recommends that the investor work closely with his or her attorney, accountant, insurance agent and other related professionals. Incorporation of the non- advisory financial product into the investor's financial plan is entirely at the Client's discretion. For insurance products, LOWA provides access to a platform of insurance products by DPL Financial Partners, LLC ("DPL"). Clients are under no obligation to use DPL's service and may seek insurance advice from any licensed agent. The insurance products and fee structures available from DPL may differ from those available from other third-party insurance agents. LOWA recommends that Clients fully evaluate products and fee structures to determine which arrangements are most favorable to the Client prior to making an investment decision. LOWA does not receive compensation for insurance products directly from the client, rather the insurance company compensates LOWA. Artificial Intelligence (AI) LOWA uses various technologies, including artificial intelligence ("AI"), to improve its business operations. • Marketing: AI tools are used to assist in drafting marketing materials, which are reviewed by human staff for accuracy. • Note-Taking: We use AI-powered, third-party tools to transcribe and summarize client meetings. These tools are used to enhance recordkeeping accuracy, and we obtain client consent prior to using them in meetings. We do not utilize AI to make investment decisions or to analyze securities. We believe the use of these tools provides operational efficiencies but acknowledge that they may introduce risks regarding data privacy. We maintain oversight of these tools to ensure they align with our fiduciary duty to our clients. Item 5: Fees and Compensation A. Fees Charged All individuals will be required to execute an agreement with LOWA outlining the services to be performed, as well as the fees for those services. Fees are negotiable. Clients are under no obligation at any time to engage or to continue to engage LOWA for investment services. If clients do not receive a copy of this brochure at least 48 hours prior to the execution of an Agreement, clients may terminate the agreement within the first five (5) business days without penalty. LOWA’s standard advisory fee is based on the market value of the assets under management. Wrap accounts are subject to the same fee schedule as non-wrap accounts as described in the LOWA Wrap Brochure. LOWA’s tiered fee schedule is as follows:  Account Value Annual Advisory Fee First $0 - $500,000 1.5% Next $500,001 - $1,000,000 1.1% 1% Next $1,000,001 - $2,000,000 Next $2,000,001 - $5,000,000 .80% Next $5,000,001 - $15,000,000 .70% Customized Next $15,000,001 and Above The fee is payable monthly in advance and is based on the average daily balance of the prior month. The advisory fee is a tiered fee and is calculated by assessing the percentage rates using the predefined levels of assets as shown in the above chart and applying the fee to the average daily balance of the prior month. No increase in the annual fee shall be effective without agreement from the Client by signing a new agreement or amendment to their current advisory agreement. The first fee payment is due upon execution of the Investment Advisory Agreement and will be assessed pro-rata in the event the agreement is executed at any time other than the first business day of a calendar quarter. The pro-rata calculation will begin on the first day of the calendar month that follows the execution of the Investment Advisory Agreement (for example, if the Investment Advisory Agreement is executed in January, pro-rata billing will begin February 1st). Lower fees may be negotiated at LOWA’s sole discretion. We do not charge our clients higher advisory fees based on their trading activity, but you should be aware that we may have an incentive to limit our trading activities in your account(s) because we are charged for executed trades. Advisory fees are directly debited from client accounts. Clients may obtain a refund of a pre-paid fee if the advisory contract is terminated before the end of the billing period, based on the amount of time remaining in the billing period. Ongoing Comprehensive Financial Planning Ongoing Comprehensive Financial Planning services are included in the monthly fee for clients with portfolio values $500,000 and above. For portfolio values below $500,000, Client shall enter into a separate financial planning arrangement which lays out the fees for this service. Additional Fees Clients referred to an Investment Manager will pay fees to that Investment Manager. There may or may not be additional fees or expenses to third parties or Investment Managers, depending on the Investment Manager and the agreement between that Investment Manager and their client. Clients should thoroughly and carefully review all materials from any Investment Manager prior to executing or otherwise entering into any agreement with an Investment Manager. Clients may incur other expenses with the implementation of advice provided such a commissions, custodian fees, or ETF expenses. None of these fees are payable to LOWA. Please refer below to Item 12, Brokerage Practices, for further information.  The combination of fees for LOWA and third-party managers will not exceed the industry standard of excessive fees, which is 3%. B. Fee Payment As stated above, fees will be based on the assets under management. The fee is paid monthly in advance and comes due on the first day of the calendar month of the stated billing cycle based on an account’s average daily balance of the prior month. In calculating the market value of a client’s assets, assets allocated to cash or a cash proxy, such as a money market account, will be included in the calculation of assets under management. Once the calculation is made, fees will be debited from the account. C. Other Fees There are no additional fees payable to LOWA. Clients referred to an Investment Manager will pay fees to that Investment Manager. There may or may not be additional fees or expenses to third parties or Investment Managers, depending on the Investment Manager and the agreement between that Investment Manager and their client. Clients should thoroughly and carefully review all materials from any Investment Manager prior to executing or otherwise entering into any agreement with an Investment Manager. Clients may incur other expenses with the implementation of advice provided such as commissions, custodian fees, or mutual fund expenses. None of these fees is payable to LOWA. D. Pro-rata Fees Accounts initiated or terminated during the month will be charged a prorated fee based on the amount of time remaining in the billing period. An account can be terminated by either party if canceled in writing. E. Compensation for the Sale of Securities This item is not applicable. Item 6: Performance-Based Fees LOWA will not charge performance-based fees. Item 7: Types of Clients We provide financial planning and portfolio management services to individuals, high net-worth individuals, charitable organizations, retirement accounts and some institutions. There is no minimum to become a client of LOWA.  Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Asset allocation strategies are developed for each client based on the financial plan created and are assigned a percentage allocated towards equity investments and a percentage allocated towards fixed income investments. Cash is not included in this allocation strategy. LOWA typically recommends that clients have two years’ worth of expenses set aside for emergency purposes or market events. LOWA almost strictly uses Exchange-traded Funds (ETF’s) as opposed to mutual funds and will go through a detailed discussion with the client on the differences between the two. Ultimately, LOWA believes ETFs are the most cost effective and tax efficient investment for most clients. The ETFs chosen for client portfolios are evaluated for cost and performance. LOWA chooses a selection of large cap growth, large cap value, small cap, international and emerging markets ETFs as the main equity pieces of the portfolio. On the fixed income side, LOWA chooses long duration, mid duration, short duration, and international bond ETFs. All ETFs are evaluated on an annual basis. LOWA uses a rebalancing strategy whereby rebalancing occurs when the market is up 5% or down 5%. Clients are notified at each rebalancing event via email and are encouraged to ask questions and/or discuss the rebalancing with their advisor at any time. Some clients may want to invest in municipal bonds or may have current investments chosen based on complex tax strategies. For such clients, LOWA may recommend the use of a third-party money manager. In selecting managers for recommendation, LOWA considers the specific expertise of the manager, the background and prior experience of each portfolio manager and the manager’s regulatory history and filings. Material Risks Involved It is important for clients to know and remember that all investments carry risks. Investing in securities involves risk and may result in a loss of clients’ original investment which clients should be prepared to bear. Market Risk: Market risk involves the possibility that an investment’s current market value will fall because of a general market decline, reducing the value of the investment regardless of the operational success of the issuer’s operations or its financial condition. Strategy Risk: The Adviser’s investment strategies and/or investment techniques may not work as intended. Small and Medium Cap Company Risk: Securities of companies with small and medium market capitalizations are often more volatile and less liquid than investments in larger companies. Small and medium cap companies may face a greater risk of business failure, which could increase the volatility of the client’s portfolio. Turnover Risk: At times, the strategy may have a portfolio turnover rate that is higher than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect the account’s performance. Limited markets: Certain securities may be less liquid (harder to sell or buy) and their prices may at times be more volatile than at other times. Under certain market conditions, we may be unable to sell  or liquidate investments at prices we consider reasonable or favorable or find buyers at any price. Concentration Risk: Certain investment strategies focus on particular asset-classes, industries, sectors or types of investment. From time to time these strategies may be subject to greater risks of adverse developments in such areas of focus than a strategy that is more broadly diversified across a wider variety of investments. Interest Rate Risk: Bond (fixed income) prices generally fall when interest rates rise, and the value may fall below par value or the principal investment. The opposite is also generally true: bond prices generally rise when interest rates fall. In general, fixed income securities with longer maturities are more sensitive to these price changes. Most other investments are also sensitive to the level and direction of interest rates. Legal or Legislative Risk: Legislative changes or Court rulings may impact the value of investments, or the securities’ claim on the issuer’s assets and finances. Inflation: Inflation may erode the buying power of your investment portfolio, even if the dollar value of your investments remains the same. Risks Associated with Securities Exchange Traded Funds: Prices may vary significantly from the Net Asset Value due to market conditions. Certain Exchange Traded Funds may not track underlying benchmarks as expected. ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value; (ii) the ETF may employ an investment strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. The Adviser has no control over the risks taken by the underlying funds in which the clients invest. Mutual Funds: When a client invests in open-end mutual funds or ETFs, the client indirectly bears its proportionate share of any fees and expenses payable directly by those funds. Therefore, the client will incur higher expenses, many of which may be duplicative. In addition, the client's overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). Alternative Asset Classes: Many alternative investments are illiquid, which means that the investments can be difficult to trade. Consequently, such holdings may limit a client's ability to dispose of such investments in a timely manner and at an advantageous price. Equity Securities: Equity securities tend to be more volatile than other investment choices. The value of an individual mutual fund or ETF can be more volatile than the market as a whole. This volatility affects the value of the client’s overall portfolio. Small and mid-cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product lines, financial resources, and less management experience than larger companies. Smaller companies may also have a lower trading volume, which may disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. Fixed Income: The issuer of a fixed income security may not be able to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the  issuer will default on its obligation. If a rating agency gives a debt security a lower rating, the value of the debt security will decline because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities held by the Fund is likely to decrease. A nominal interest rate is the sum of a real interest rate and an expected inflation rate. Real Estate Investment Trust (REIT): A REIT is an entity, typically a trust or corporation that accepts investments from a number of investors, pools the money, and then uses that money to invest in real estate through either actual property purchases or mortgage loans. While there are some benefits to owning REITs, which include potential tax benefits, income, and the relatively low barrier to invest in real estate as compared to directly investing in real estate, REITs also have some increased risks as compared to more traditional investments such as stocks, bonds, and mutual funds. First, real estate investing can be highly volatile. Second, the specific REIT chosen may have a focus such as commercial real estate or real estate in a given location. Such investment focus can be beneficial if the properties are successful but lose significant principal if the properties are not successful. REITs may also employ significant leverage for the purpose of purchasing more investments with fewer investment dollars, which can enhance returns but also enhances the risk of loss. The success of a REIT is highly dependent upon the manager of the REIT. Clients should ensure they understand the role of the REIT in their portfolio. Long-Short Direct Indexing: Shorting stocks introduces the potential for theoretically unlimited losses, as the price of a shorted stock can rise indefinitely. Shorting also incurs borrowing fees, dividend liabilities, and potential buy-in risks. This is speculative and carries theoretically unlimited risk of loss, as there is no cap on how high a security's price may rise before the position is closed. Using margin to achieve 130/30 or higher long/short ratios amplifies both potential gains and losses. There is a risk of forced liquidation or margin calls if the short positions rise in value, severely magnifying portfolio drawdowns. The strategy attempts to track an index (such as the S&P 500) while actively harvesting losses and maintaining short positions. This deviation can lead to persistent underperformance relative to the benchmark index. The strategy relies on complex tax-loss harvesting. The IRS requires these extension strategies to have "economic substance" beyond mere tax benefits, and changes in tax laws could render the strategy less effective or generate unexpected capital gains. Frequent trading to harvest losses (while continuously rebalancing long and short positions) increases transaction costs, which can offset much of the intended "tax alpha" or post-tax returns. Item 9: Disciplinary Information Criminal or Civil Actions LOWA and its management have not been involved in any criminal or civil action. Administrative Enforcement Proceedings LOWA and its management have not been involved in administrative enforcement proceedings. Self-Regulatory Organization Enforcement Proceedings LOWA and its management have not been involved in legal or disciplinary events that are material to a Client’s or prospective Client’s evaluation of LOWA or the integrity of its management.  Item 10: Other Financial Industry Activities and Affiliations A. Broker-dealer None of the principals of LOWA, nor any related persons are registered, or have an application pending to register, as a broker dealer or as an associated person of the foregoing entities. B. Futures Commission Merchant/Commodity Trading Advisor None of the principals of LOWA, nor any related persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. C. Relationship with Related Persons Mr. DiLeonardo and Mr. Petit-Homme are the owners of Liberty One Private Risk, ("LOPR"). LOPR offers insurance-related legal services. It is expected that some clients of our firm may become clients of LOPR and vice versa. However, you are advised that you are under no obligation to utilize either the insurance services offered by LOPR, or the advisory services offered through our firm or our Associated Persons. Advisory services and fees offered through our firm are separate and distinct from the insurance services and fees offered through LOPR. D. Recommendations of Other Advisers and Insurance Agencies LOWA may at times recommend unrelated, third-party investment managers or professionals who have a greater expertise in certain disciplines when appropriate for the client. We do not receive any compensation from the unrelated, third-party investment managers or professionals, nor do we charge any additional fee to our clients for the recommendation of selection of third-party investment managers or professionals. E. Licensed Insurance Brokers One or more of LOWA’s Supervised Persons are licensed insurance brokers and offer certain insurance products on a fully disclosed commissionable basis. A conflict of interest exists to the extent that LOWA recommends the purchase of insurance products where its Supervised Persons are entitled to insurance commissions or other additional compensation. LOWA has procedures in place whereby it seeks to ensure that all recommendations are made in its clients’ best interest regardless of any such affiliations. Item 11: Code of Ethics, Participation, or Interest in Client Transactions and Personal Trading A. A copy of the Code of Ethics is available upon request. Our Code of Ethics includes discussions of our fiduciary duty to clients, political contributions, gifts, and entertainment. B. LOWA does not recommend to clients that they invest in any security in which LOWA, or any principal thereof has any financial interest.  C. Firm principals may at some point recommend and choose to invest in a security in their personal account that is already in, or being considered for, a client account. Principals will not place personal trades before client trades in the same security. D. Firm Principals may at some point choose to invest in a security in their personal account at the same time that security is being traded for or being considered for, a client account. Principals will not place personal trades before client trades in the same security at the same time. Item 12: Brokerage Practices Factors Used to Select Custodians and/or Broker-Dealers LOWA does not have any affiliation with Broker-Dealers. Specific custodian recommendations are made to the client based on their need for such services. LOWA recommends custodians based on the reputation and services provided by the firm. 1. Research and Other Soft-Dollar Benefits LOWA does not receive soft dollar benefits. 2. Brokerage for Client Referrals LOWA receives no referrals from a broker-dealer or third party in exchange for using that broker- dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use LOWA recommends a specific custodian for clients to use. Not all advisers require their clients to direct brokerage. The Custodian and Broker Used (Charles Schwab) The custodian and broker LOWA uses maintains custody of client assets that LOWA manages, although LOWA may be deemed to have limited custody of your assets due to the ability to withdraw fees from client accounts (see Item 15 – Custody, below). LOWA recommends that clients use Charles Schwab & Co., Inc. (“Schwab”), a registered broker-dealer, member SIPC, as the qualified custodian. LOWA is independently owned and operated and is not affiliated with Schwab. Aggregating Orders for Various Client Accounts When executing a trade in various accounts, LOWA aggregates the trade by purchasing the security during the day and averaging the price paid. Each client pays the average price.  Item 13: Review of Accounts All client profiles will be managed on an ongoing basis, with formal reviews with the client on at least an annual basis. However, it is expected that market conditions, changes in a particular client’s account, or changes to a client’s circumstances will trigger a review of accounts. The annual report in writing provided by LOWA is intended to review asset allocation. All clients will receive statements and confirmations of trades directly from their custodians. Item 14: Client Referrals and Other Compensation A. Economic Benefit Provided by Third Parties for Advice Rendered to Client. This item is not applicable, as LOWA is not provided any economic benefit by third parties for providing services to clients. B. Compensation to Non-Advisory Personnel for Client Referrals. LOWA has contracted with Cr1sp, LLC to act as an independent solicitor to provide client referrals. If a client is referred to us by this solicitor, this practice is disclosed to the client in writing by the solicitor and LOWA pays the solicitor out of its own funds—specifically, LOWA generally pays the solicitor a portion of the advisory fees earned for managing the capital of the client or investor that was referred. The use of solicitors is strictly regulated under applicable federal and state law. LOWA’s policy is to fully comply with the requirements of Rule 206(4) -3, under the Investment Advisers Act of 1940, as amended, and similar state rules, as applicable. LOWA will perform and document periodic reviews of referral activity to confirm procedures are being followed. LOWA will make it clear to each client referred that the company may receive income from the arrangement. Item 15: Custody LOWA has the ability to have its advisory fee for each client debited by the custodian on a quarterly basis. Clients are provided, at least quarterly, with written transaction confirmation notices and regular written summary account statements directly from the broker-dealer/custodian and/or program sponsor for the client accounts. Client should carefully review any statement received from the account custodian. Although the payment of adviser fees directly from a client’s account is deemed custody, the custody requirements of Regulation 303.042 are not applicable as LOWA complies with the following procedures: • LOWA possesses written authorization from clients to deduct advisory fees from an account held by a qualified custodian; • LOWA sends the qualified custodian written notice of the amount of the fee to be deducted from the client’s account; and  • LOWA sends the client a written invoice itemizing the fee, including any formulae used to calculate the fee, the time period covered by the fee and the amount of assets under management on which the fee was based. Item 16: Investment Discretion For those Client accounts where LOWA provides Investment Management Services, LOWA maintains discretion over client accounts with respect to securities to be bought and sold and the amount of securities to be bought and sold. Investment discretion is explained to clients in detail when an advisory relationship has commenced. At the start of the advisory relationship, the client will execute a Limited Power of Attorney, which will grant our firm discretion over the account. Additionally, the discretionary relationship will be outlined in the advisory contract and signed by the client. For clients who engage LOWA on a non-discretionary basis, while there will be an ongoing relationship with each client, being involved in various stages of their lives and decisions to be made, LOWA will seek specific approval of changes to client accounts before any changes are made. Clients can always make deposits or withdrawals in their accounts at any time. Clients will be responsible for executing an Investment Management Agreement that outlines the responsibilities of both the client and LOWA. Item 17: Voting Client Securities Copies of our Proxy Voting Policies are available upon request. From time to time, shareholders of stocks, mutual funds, exchange traded funds or other securities may be permitted to vote on various types of corporate actions. Examples of these actions include mergers, tender offers, or board elections. Clients are required to vote proxies related to their investments, or to choose not to vote their proxies. LOWA will not accept authority to vote client securities. Clients will receive their proxies directly from the custodian for the client account. Upon a client’s request, LOWA will give clients advice on how to vote proxies, but it is the responsibility of the client and the outside managers to vote client securities. For questions about proxies or other solicitations, please contact us at 215-776-4918 or via email at gdileonardo@libertyonewealth.com. Item 18: Financial Information LOWA does not require the prepayment of fees more than six (6) months or more in advance and therefore has not provided a balance sheet with this brochure. There are no material financial circumstances or conditions that would reasonably be expected to impair our ability to meet our contractual obligations to our clients.  Item 1: Cover Sheet FORM ADV PART 2A APPENDIX 1 WRAP FEE PROGRAM BROCHURE LIBERTY ONE WEALTH ADVISORS 2001 Market St, Suite 2500 Philadelphia, PA 19103 www.libertyonewealth.com Guilian DiLeonardo 215-776-4918 July 1, 2026 This wrap fee program brochure provides information about the qualifications and business practices of Liberty One Wealth Advisors. If you have any questions about the contents of this brochure, please contact us at 215-776-4918 or via email at gdileonardo@libertyonewealth.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. Liberty One Wealth Advisors is registered as an Investment Adviser with the Securities and Exchange Commission. Our registration does not imply a certain level of skill or training. Additional information about Liberty One Wealth Advisors is also available on the SEC’s website at www.adviserinfo.sec.gov.  Item 2: Statement of Material Changes In this Item, Liberty One Wealth Advisors is required to discuss any material changes that have been made to the brochure since the last annual updating amendment. Since the last filing, there have been no material changes.  Item 3: Table of Contents TABLE OF CONTENTS Item 1: Cover Sheet 16 Item 2: Statement of Material Changes 17 Item 3: Table of Contents 18 Item 4: Service, Fees, and Compensation 19 Item 5: Account Requirements and Types of Clients 22 Item 9: Performance-Based Fees 22 Item 10: Types of Clients 23 Item 11: Methods of Analysis, Investment Strategies and Risk of Loss 23 Other Financial Industry Activities and Affiliations 26 Code of Ethics, Participation, or Interest in Client Transactions and Personal Trading 27 Review of Accounts 27 Client Referrals and Other Compensation 27  WRAP FEE PROGRAM BROCHURE LIBERTY ONE WEALTH ADVISORS Item 4: Service, Fees, and Compensation Liberty One Wealth Advisors (“LOWA”) offers a wrap fee program whereby the firm manages client accounts for a single convenient wrap fee that includes investment advisory services, portfolio management services, custody and clearance services and transaction costs. Additionally, certain of LOWA’s Supervised Persons, in their individual capacities, offer insurance products under a separate commission-based arrangement. LOWA serves as the portfolio manager and seeks long-term growth of clients’ financial assets while emphasizing preservation of capital. Prior to engaging LOWA to provide services through the wrap fee program, the client is required to enter into an Investment Management Agreement with LOWA which sets forth the terms and conditions of the engagement and the scope of services to be provided. Clients may impose restrictions on investing in specific securities, industries, or sectors. Advisory Fee LOWA charges a single convenient “wrap fee” for these services. The fee is payable monthly in advance and is based on the average daily balance of the prior month. The first fee payment is due upon execution of the Investment Advisory Agreement and will be assessed pro-rata in the event the agreement is executed at any time other than the first business day of a calendar quarter. The pro-rata calculation will begin on the first day of the calendar month that follows the execution of the Investment Advisory Agreement (for example, if the Investment Advisory Agreement is executed in January, pro-rata billing will begin February 1st). Lower fees may be negotiated at LOWA’s sole discretion. We do not charge our clients higher advisory fees based on their trading activity, but you should be aware that we may have an incentive to limit our trading activities in your account(s) because we are charged for executed trades. Advisory fees are directly debited from client accounts. Clients may obtain a refund of a pre-paid fee if the advisory contract is terminated before the end of the billing period, based on the amount of time remaining in the billing period. In addition to compensating LOWA for advisory services, the wrap fee you pay LOWA allows us to pay for brokerage and execution services provided by Schwab. In addition to the advisory services, the wrap fee program includes certain brokerage services of Charles Schwab & Co., Inc. ("Schwab"), a broker-dealer registered with the Securities and Exchange Commission and a member of FINRA and SIPC. We are independently owned and operated and not affiliated with Schwab. Schwab will act solely as a broker-dealer and not as an investment advisor to you. Schwab will have no discretion over your account and will act solely on instructions it receives from us [or you]. Schwab has no responsibility for our services and undertakes no duty to you to monitor our firm's management of your account or other services we provide to you. Schwab will hold your assets in a brokerage account and buy and sell securities and execute other transactions when we [or you] instruct them to. We do not open the account for you. LOWA pays Schwab a single asset-based fee in lieu of transaction-based commissions. The fees we pay Schwab are assessed on certain assets in your account(s) at Schwab. The benefits under a wrap fee program depend, in part, upon the size of the account, the costs associated with managing the account, and the frequency or type of securities transactions executed in the account. For example, a wrap fee program may not be suitable for all accounts, including but not limited to accounts holding primarily, and for any substantial period of time, cash or cash equivalent investments, fixed income securities or no-transaction-fee mutual funds, or any other type of security that can be traded without commissions or  other transaction fees. In order to evaluate whether a wrap [or bundled] fee arrangement is appropriate for you, you should compare the agreed-upon Wrap Program Fee and any other costs associated with participating in our Wrap Fee Program with the amounts that would be charged by other advisers, broker-dealers, and custodians, for advisory fees, brokerage and execution costs, and custodial services comparable to those provided under the Wrap Fee Program. A wrap fee is not based directly on the number of transactions in your account. Various factors influence the relative cost of our wrap fee program to you, including the cost of our investment advice, custody and brokerage services if you purchased them separately, the types of investments held in your account, and the frequency, type and size of trades in your account. The program could cost you more or less than purchasing our investment advice and custody/brokerage services separately. LOWA’s standard advisory fee is based on the market value of the assets under management and is calculated as follows: Account Value Annual Advisory Fee First $0 - $500,000 1.5% Next $500,001 - $1,000,000 1.1% 1% Next $1,000,001 - $2,000,000 Next $2,000,001 - $5,000,000 .80% Next $5,000,001 - $15,000,000 .70% Customized Next $15,000,001 and Above Schwab generally does not charge commissions [or transaction fees] for online trades of U.S. exchange-listed securities (including U.S. exchange-listed ETFs), options (subject to $0.65 per contract fee), and no- transaction-fee ("NTF") funds. This means that, in most cases, when we buy these types of securities, we can do so without paying any commissions to Schwab. We encourage you to review Schwab's pricing to compare the total costs of entering into a wrap fee arrangement versus a non-wrap fee arrangement. If you choose to enter into a wrap fee arrangement, your total cost to invest could exceed the cost of paying for brokerage and advisory services separately. Ongoing Comprehensive Financial Planning Ongoing Comprehensive Financial Planning services are included in the monthly fee for clients with portfolio values $500,000 and above. For portfolio values below $500,000, Client shall enter into a separate financial planning arrangement which lays out the fees for this service. Other Charges Clients referred to an Investment Manager will pay fees to that Investment Manager. There may or may not be additional fees or expenses to third parties or Investment Managers, depending on the Investment Manager and the agreement between that Investment Manager and their client. Clients should thoroughly and carefully  review all materials from any Investment Manager prior to executing or otherwise entering into any agreement with an Investment Manager. Clients may incur other expenses with the implementation of advice provided such a commissions, custodian fees, or ETF expenses. None of these fees are payable to LOWA. For accounts in the Wrap Program, LOWA pays a fee to the account custodian based on the total amount of client assets enrolled in the Wrap Program, thus taking on many of the clients’ transactions cost. Fees included in the wrap fee include transaction fees for the purchase or sale of securities, but do not include expenses related to the use of margin, wire transfer fees, the fees charged to shareholders of mutual funds or ETFs, mark-ups and mark- downs, spreads, odd-lot differentials, fees charged by regulatory agencies, and any transaction fees for securities trades executed by a broker-dealer other than the primary custodian. Expenses for the management fees of third-party managers are also not included in the Wrap Program, and to the extent utilized, you will be responsible for such fees. There is no difference between how LOWA manages wrap fee accounts and how LOWA manages other accounts. Please refer below to Item 12, Brokerage Practices, for further information. Compensation for Recommending the Wrap Fee Program LOWA has no arrangements in place whereby persons recommending the wrap fee program are entitled to receive additional compensation as a result of clients’ participation. Products & Services Available to Us From Schwab - Schwab Advisor Services (formerly called Schwab Institutional) is Schwab’s business serving independent investment advisory firms like ours. They provide us and our clients with access to its institutional brokerage – trading, custody, reporting and related services – many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts while others help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis and at no charge to us as long as we maintain a total of at least $10 million of our clients’ assets in accounts at Schwab. Schwab has eliminated commissions for online trades of equities, ETFs, and options (subject to $0.65 per contract fee). This means that, in most cases, when we buy and sell these types of securities, we will not have to pay any commissions to Schwab. We encourage you to review Schwab’s pricing to compare the total costs of entering into a wrap fee arrangement versus a non-wrap fee arrangement. If you choose to enter into a wrap fee arrangement, your total cost to invest could exceed the cost of paying for brokerage and advisory services separately. To see what you would pay for transactions in a non-wrap account please refer to Schwab’s most recent pricing schedules available at schwab.com/aspricingguide Services that Benefit Client - Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit clients. Services that May Not Directly Benefit Clients - Schwab also makes available to us other products and services that benefit us but may not directly benefit the client or their account(s). These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or some 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: facilitates trade execution and allocate aggregated trade orders for multiple client accounts; facilitates payment of our fees from our clients’ accounts; and • provides access to client account data (such as duplicate trade confirmations and account statements); • • provides pricing and other market data; •  assists with back-office functions, recordkeeping and client reporting. • educational conferences and events technology, compliance, legal, and business consulting; access to employee benefits providers, human capital consultants and insurance providers. Schwab offers other services intended to help us manage and develop our business enterprise. These services include: • • • publications and conferences on practice management and business succession; and • Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Assets under Management As of December 31, 2025, LOWA has approximately $178,357,037 in assets under management over 832 accounts, all of which are managed on a discretionary basis. Item 5: Account Requirements and Types of Clients We provide financial planning and portfolio management services to individuals, high net-worth individuals, charitable organizations, retirement accounts and some institutions. There is no minimum to become a client of LOWA. Item 6: Portfolio Manager Selection and Evaluation The wrap fee program offered by LOWA is sponsored by the firm’s custodian, Schwab, and LOWA is the only portfolio manager. The only fees covered under the wrap fee program are transaction fees associated with the purchase and sale of securities in an account managed by LOWA. All client accounts managed by LOWA, including wrap fee program clients, are managed with similar processes, although account recommendations may differ. Item 7: Client Information Provided to Portfolio Managers When evaluating the recommendations for a client, LOWA considers their income level/tax rate, risk tolerance, and overall financial picture to get a strong idea of what’s best for them. With that in mind, LOWA makes recommendations around their investment management, noting the risk profile of the 3rd party manager and cost to the client. LOWA ensures all client questions are answered and they are fully aware of the risks involved in anything they are investing in. Item 8: Client Contact with Portfolio Managers Clients may contact LOWA, the only portfolio manager, at any time. Item 9: Performance-Based Fees LOWA will not charge performance-based fees.  Item 10: Types of Clients We provide financial planning and portfolio management services to individuals, high net-worth individuals, charitable organizations and some institutions. There is no minimum to become a client of LOWA. Item 11: Methods of Analysis, Investment Strategies and Risk of Loss Asset allocation strategies are developed for each client based on the financial plan created and are assigned a percentage allocated towards equity investments, a percentage allocated towards fixed income investments, and if suitable a percentage allocated towards alternative investments. Cash is not included in this allocation strategy. LOWA typically recommends that clients have two years’ worth of expenses set aside for emergency purposes or market events. LOWA almost strictly uses Exchange-traded Funds (ETF’s) as opposed to mutual funds and will go through a detailed discussion with the client on the differences between the two. Ultimately, LOWA believes ETFs are the most cost effective and tax efficient investment for most clients. The ETFs chosen for client portfolios are evaluated for cost and performance. LOWA chooses a selection of large cap growth, large cap value, small cap, international and emerging markets ETFs as the main equity pieces of the portfolio. On the fixed income side, LOWA chooses long duration, mid duration, short duration, and international bond ETFs. All ETFs are evaluated on an annual basis. LOWA may also choose alternative asset categories that are suitable in light of the client's investment goals, objectives, and risk tolerance. These alternative investments may include, but are not limited to, gold, real estate, venture capital limited partnerships, private equity, managed future funds, hedge funds, and third-party funds of funds. LOWA uses a rebalancing strategy whereby rebalancing occurs when the market is up 5% or down 5%. Clients are notified at each rebalancing event via email and are encouraged to ask questions and/or discuss the rebalancing with their advisor at any time. Some clients may want to invest in municipal bonds or may have current investments chosen based on complex tax strategies. For such clients, LOWA may recommend the use of a third-party money manager. In selecting managers for recommendation, LOWA considers the specific expertise of the manager, the background and prior experience of each portfolio manager and the manager’s regulatory history and filings. Material Risks Involved It is important for clients to know and remember that all investments carry risks. Investing in securities involves risk and may result in a loss of clients’ original investment which clients should be prepared to bear. Market Risk: Market risk involves the possibility that an investment’s current market value will fall because of a general market decline, reducing the value of the investment regardless of the operational success of the issuer’s operations or its financial condition. Strategy Risk: The Adviser’s investment strategies and/or investment techniques may not work as intended. Small and Medium Cap Company Risk: Securities of companies with small and medium market capitalizations are often more volatile and less liquid than investments in larger companies. Small and medium cap companies may face a greater risk of business failure, which could increase the volatility  of the client’s portfolio. Turnover Risk: At times, the strategy may have a portfolio turnover rate that is higher than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect the account’s performance. Limited markets: Certain securities may be less liquid (harder to sell or buy) and their prices may at times be more volatile than at other times. Under certain market conditions, we may be unable to sell or liquidate investments at prices we consider reasonable or favorable or find buyers at any price. Concentration Risk: Certain investment strategies focus on particular asset-classes, industries, sectors or types of investment. From time to time these strategies may be subject to greater risks of adverse developments in such areas of focus than a strategy that is more broadly diversified across a wider variety of investments. Interest Rate Risk: Bond (fixed income) prices generally fall when interest rates rise, and the value may fall below par value or the principal investment. The opposite is also generally true: bond prices generally rise when interest rates fall. In general, fixed income securities with longer maturities are more sensitive to these price changes. Most other investments are also sensitive to the level and direction of interest rates. Legal or Legislative Risk: Legislative changes or Court rulings may impact the value of investments, or the securities’ claim on the issuer’s assets and finances. Inflation: Inflation may erode the buying power of your investment portfolio, even if the dollar value of your investments remains the same. Risks Associated with Securities Exchange Traded Funds: Prices may vary significantly from the Net Asset Value due to market conditions. Certain Exchange Traded Funds may not track underlying benchmarks as expected. ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value; (ii) the ETF may employ an investment strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. The Adviser has no control over the risks taken by the underlying funds in which the clients invest. Mutual Funds: When a client invests in open-end mutual funds or ETFs, the client indirectly bears its proportionate share of any fees and expenses payable directly by those funds. Therefore, the client will incur higher expenses, many of which may be duplicative. In addition, the client's overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). When selecting mutual funds that have multiple share classes for recommendation to clients, we will take into account the internal fees and expenses associated with each share class, as it is our policy to choose the lowest-cost share class available, absent circumstances that dictate otherwise. Alternative Asset Classes: Many alternative investments are illiquid, which means that the investments can be difficult to trade. Consequently, such holdings may limit a client's ability to dispose of such investments in a timely manner and at an advantageous price.  Equity Securities: Equity securities tend to be more volatile than other investment choices. The value of an individual mutual fund or ETF can be more volatile than the market as a whole. This volatility affects the value of the client’s overall portfolio. Small and mid-cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product lines, financial resources, and less management experience than larger companies. Smaller companies may also have a lower trading volume, which may disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. Fixed Income: The issuer of a fixed income security may not be able to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower rating, the value of the debt security will decline because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities held by the Fund is likely to decrease. A nominal interest rate is the sum of a real interest rate and an expected inflation rate. Real Estate Investment Trust (REIT): A REIT is an entity, typically a trust or corporation that accepts investments from a number of investors, pools the money, and then uses that money to invest in real estate through either actual property purchases or mortgage loans. While there are some benefits to owning REITs, which include potential tax benefits, income, and the relatively low barrier to invest in real estate as compared to directly investing in real estate, REITs also have some increased risks as compared to more traditional investments such as stocks, bonds, and mutual funds. First, real estate investing can be highly volatile. Second, the specific REIT chosen may have a focus such as commercial real estate or real estate in a given location. Such investment focus can be beneficial if the properties are successful but lose significant principal if the properties are not successful. REITs may also employ significant leverage for the purpose of purchasing more investments with fewer investment dollars, which can enhance returns but also enhances the risk of loss. The success of a REIT is highly dependent upon the manager of the REIT. Clients should ensure they understand the role of the REIT in their portfolio. Long-Short Direct Indexing: Shorting stocks introduces the potential for theoretically unlimited losses, as the price of a shorted stock can rise indefinitely. Shorting also incurs borrowing fees, dividend liabilities, and potential buy-in risks. This is speculative and carries theoretically unlimited risk of loss, as there is no cap on how high a security's price may rise before the position is closed. Using margin to achieve 130/30 or higher long/short ratios amplifies both potential gains and losses. There is a risk of forced liquidation or margin calls if the short positions rise in value, severely magnifying portfolio drawdowns. The strategy attempts to track an index (such as the S&P 500) while actively harvesting losses and maintaining short positions. This deviation can lead to persistent underperformance relative to the benchmark index. The strategy relies on complex tax-loss harvesting. The IRS requires these extension strategies to have "economic substance" beyond mere tax benefits, and changes in tax laws could render the strategy less effective or generate unexpected capital gains. Frequent trading to harvest losses (while continuously rebalancing long and short positions) increases transaction costs, which can offset much of the intended "tax alpha" or post-tax returns. Item 12: Additional Information Disciplinary Information  A. Criminal or Civil Actions LOWA and its management have not been involved in any criminal or civil action. B. Administrative Enforcement Proceedings LOWA and its management have not been involved in administrative enforcement proceedings. C. Self-Regulatory Organization Enforcement Proceedings LOWA and its management have not been involved in legal or disciplinary events that are material to a Client’s or prospective Client’s evaluation of LOWA or the integrity of its management. Other Financial Industry Activities and Affiliations F. Broker-dealer None of the principals of LOWA, nor any related persons are registered, or have an application pending to register, as a broker dealer or as an associated person of the foregoing entities. G. Futures Commission Merchant/Commodity Trading Advisor None of the principals of LOWA, nor any related persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. H. Relationship with Related Persons Mr. DiLeonardo and Mr. Petit-Homme are the owners of Liberty One Private Risk, ("LOPR"). LOPR offers insurance-related legal services. It is expected that some clients of our firm may become clients of LOPR and vice versa. However, you are advised that you are under no obligation to utilize either the insurance services offered by LOPR, or the advisory services offered through our firm or our Associated Persons. Advisory services and fees offered through our firm are separate and distinct from the insurance services and fees offered through LOPR. I. Recommendations of Other Advisers LOWA may at times recommend unrelated, third-party investment managers or professionals who have a greater expertise in certain disciplines when appropriate for the client. We do not receive any compensation from the unrelated, third-party investment managers or professionals, nor do we charge any additional fee to our clients for the recommendation to selection of third-party investment managers or professionals. J. Licensed Insurance Brokers One or more of LOWA’s Supervised Persons are licensed insurance brokers and offer certain insurance products on a fully disclosed commissionable basis. A conflict of interest exists to the extent that LOWA recommends the purchase of insurance products where its Supervised Persons are entitled to insurance commissions or other additional compensation. LOWA has procedures in place whereby it seeks to ensure that all recommendations are made in its clients’ best interest regardless of any such affiliations.  Code of Ethics, Participation, or Interest in Client Transactions and Personal Trading E. A copy of the Code of Ethics is available upon request. Our Code of Ethics includes discussions of our fiduciary duty to clients, political contributions, gifts, and entertainment. F. LOWA does not recommend to clients that they invest in any security in which LOWA, or any principal thereof has any financial interest. G. Firm principals may at some point recommend and choose to invest in a security in their personal account that is already in, or being considered for, a client account. Principals will not place personal trades before client trades in the same security. H. Firm Principals may at some point choose to invest in a security in their personal account at the same time that security is being traded for or being considered for, a client account. Principals will not place personal trades before client trades in the same security at the same time. Review of Accounts All client profiles will be managed on an ongoing basis, with formal reviews with the client on at least an annual basis. However, it is expected that market conditions, changes in a particular client’s account, or changes to a client’s circumstances will trigger a review of accounts. The annual review conducted by LOWA is intended to review asset allocation. All clients will receive statements and confirmations of trades directly from their custodians. Client Referrals and Other Compensation LOWA has contracted with Cr1sp, LLC to act as an independent solicitor to provide client referrals. If a client is referred to us by this solicitor, this practice is disclosed to the client in writing by the solicitor and LOWA pays the solicitor out of its own funds—specifically, LOWA generally pays the solicitor a portion of the advisory fees earned for managing the capital of the client or investor that was referred. The use of solicitors is strictly regulated under applicable federal and state law. LOWA’s policy is to fully comply with the requirements of Rule 206(4) -3, under the Investment Advisers Act of 1940, as amended, and similar state rules, as applicable. LOWA will perform and document periodic reviews of referral activity to confirm procedures are being followed. LOWA will make it clear to each client referred that the company may receive income from the arrangement. Financial Information LOWA does not require the prepayment of fees more than six (6) months or more in advance and therefore has not provided a balance sheet with this brochure. There are no material financial circumstances or conditions that would reasonably be expected to impair our ability to meet our contractual obligations to our clients.