LOFTIN WEALTH PARTNERS

Part 2A of Form ADV: Firm Brochure Form ADV, Part 2A, Item 1 Cover Page GER Loftin Wealth Advisors, LLC, DBA: Loftin Wealth Partners 6470 E. Johns Crossing, Suite 230 Johns Creek, GA 30097 Tel: (888) 556-3846 Website: www.loftinwealthpartners.com April 30, 2026 FORM ADV PART 2 FIRM BROCHURE This brochure provides information about the qualifications and business practices of Loftin Wealth Partners. If you have any questions about the contents of this brochure, please contact us at (888) 556- 3846. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Loftin Wealth Partners is also available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Loftin Wealth Partners is 305359. Loftin Wealth Partners 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. 1  Form ADV, Part 2A, Item 2 Material Changes Annual Update The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of the Firm Brochure. Each year, we will ensure that you receive a summary of any material changes to this and subsequent brochures by April 30th. We will further provide you with our most recent brochure at any time at your request, without charge. You may request a brochure by contacting us at (888) 556-3846. Material Changes since the Last Update Loftin Wealth Partners was established as a new Registered Investment Advisor in September 2019 under the United States Securities and Exchange Commission (SEC) rules and regulations. The following changes have been made since the firm’s last annual update on March 17, 2025: • None. 2  Form ADV, Part 2A, Item 3 Table of Contents Advisory Business………………………………………………………………….. 4 Fees and Compensation…………………………………………………………… 5 Performance-Based Fees and Side-By-Side Management………………….. 7 Types of Clients……………………………………………………………………… 7 Methods of Analysis, Investment Strategies, and Risk of Loss……………. 7 Disciplinary Information…………………………………………………………… 10 Other Financial Industry Activities and Affiliations…………………………. 10 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading………………………………………………………………………………. 10 Brokerage Practices………………………………………………………………. 11 Review of Accounts……………………………………………………………….. 12 Client Referrals and Other Compensation…………………………………….. 13 Custody………………………………………………………………………………. 13 Investment Discretion………………………………………………………………14 Voting Client Securities…………………………………………………………… 14 Financial Information……………………………………………………………… 14 Requirements for State-Registered Advisers…………………………………. 15 3  Form ADV Part 2A, Item 4 Advisory Business Loftin Wealth Partners (hereinafter called “LWP”) is an SEC-registered investment adviser based in Johns Creek, Georgia, organized under the laws of the State of Georgia and owned by James Loftin. LWP has been registered with the SEC as an investment adviser since September 2019 and is subject to its rules and regulations. LWP provides investment advisory services tailored to each client's objectives, time horizon, and risk tolerance. Services include portfolio management, asset allocation, investment planning, estate planning, financial organization, and financial decision-making. Clients may restrict investment in certain securities, types of securities, sectors, or companies by providing written notice; email constitutes acceptable written notification. LWP also provides financial planning consulting services including, but not limited to, risk assessment/management, investment planning, estate planning, financial organization, or financial decision making/negotiation. LWP delivers advisory services through its Investment Advisory Representatives ("IARs”) to individuals, charitable organizations, and corporations. LWP offers both discretionary and non- discretionary managed account programs and assists clients in determining the suitability of each program. Advisory fees are charged as a single comprehensive fee; certain accounts may also be subject to additional charges associated with brokerage services. LWP and its IARs are responsible for the following: • Performing due diligence • Recommending strategic asset and style allocations • Providing research on investment product options, as needed • Providing client risk profile questionnaire • Obtaining investment advisory contract from client with required financial, risk tolerance, suitability and investment vehicle selection information for each new account • Performing client suitability check on account documentation, review the investment objectives and evaluate the investment vehicle selections • Providing Firm Brochure (this document) LWP may recommend a Wrap Fee Program for the client’s account(s). A “wrap fee program” for purposes of the SEC is a program under which investment advisory and brokerage execution services are provided for a single “wrapped” fee that is not based on the transactions in a client account. Clients with Wrap Fee Program accounts will be provided with LWP’s Wrap Fee Brochure. Assets Under Management As of January 2, 2026, LWP manages $344,490,661 in discretionary client assets and $0 in non- discretionary assets. 4  Form ADV, Part 2A, Item 5 Fees and Compensation The following types of fees will be assessed: Asset Management – Fees are charged in advance and are based primarily on asset size and the level of complexity of the services provided. In individual cases, LWP has the sole discretion to negotiate fees that are lower than the standard fee shown or to waive fees. Fees are not based on the share of capital gains or capital appreciation of the funds or any portion of the funds. Comparable services for lower fees may be available from other sources. Fees for the initial quarter will be prorated based upon the number of calendar days in the calendar quarter that the advisory agreement is in effect. Fees are based on the market value of the assets on the last business day of the previous quarter. Annual fees range from 1.25% - 1.50%, depending on the amount of assets under management (“AUM”) – See chart below. Consulting services are included in these fees for asset management services with the exception of unique circumstances that may require a separate agreement for financial planning services (description and fees are discussed below). If the situation warrants separate financial planning fees, it will be discussed upfront and a separate agreement will be negotiated. Fee Schedule for Asset Management: Total Account Value Maximum Annual Advisory Fee Under $5,000,000 1.50% 1.25% $5,000,000 or more As authorized in the client agreement, the account custodian withdraws Loftin Wealth Partners’ advisory fees directly from the clients’ accounts according to the custodian’s policies, practices, and procedures. The custodial statement includes the amount of any fees paid to LWP for advisory services. You should carefully review the statement from your custodian/broker-dealer’s statement and verify the calculation of fees. Your custodian/broker-dealer does not verify the accuracy of fee calculations. Fees are charged in advance on a quarterly basis, meaning that advisory fees for a quarter are charged on the first day of the quarter. Clients may terminate investment advisory services obtained from LWP, without penalty, upon written notice within five (5) business days after entering into the advisory agreement with LWP. The client is responsible for any fees and charges incurred by the client from third parties as a result of maintaining the account such as transaction fees for any securities transactions executed and account maintenance or custodial fees. Thereafter, the client may terminate advisory services upon written notice delivered to and received by LWP. Clients who terminate investment advisory services during a quarter are charged a prorated advisory fee based on the date of LWP’s receipt of client’s written notice to terminate. Any earned but unpaid fees are immediately due and payable, and any prepaid and unearned fees will be immediately refunded. Financial Planning – Financial planning services are charged in advance through a fixed fee or hourly arrangement as agreed upon between the client and Loftin Wealth Partners. There will never be an instance where $1,200 or more in fees is charged six or more months in advance. Hourly fees are generally charged when the scope of services cannot be determined or if the services are limited to one meeting. Fixed fees are generally quoted to the client for longer term consulting projects. Fees are 5  negotiable and vary depending upon the complexity of the client situation and services to be provided. Hourly fees range from $250 - $500 per hour, depending on what is negotiated between LWP and the client. Similar financial planning services may be available elsewhere for a lower cost to the client. Fixed fees for longer-term consulting projects range from $250 to $5,000 per project. An estimate for total hours and charges is determined at the start of the advisory relationship. Typically, clients will be invoiced monthly for all time spent by LWP as agreed upon by client or upon completion of the services if less than a month. Clients who wish to terminate the planning process prior to completion may do so with written notice. The client may obtain a refund of a pre-paid fee if the advisory contract is terminated before the end of the billing period by contacting James Loftin at (888) 556-3846. Upon receipt of written notification, any earned fee will immediately become due and payable, and any prepaid and unearned fees will be immediately refunded. A client may terminate an advisory agreement without being assessed any fees or expenses within five (5) days of its signing. Additional Fees and Expenses In addition to advisory fees paid to LWP as explained above, clients may pay custodial service, account maintenance, transaction, and other fees associated with maintaining the account. These fees vary by broker and/or custodian. Clients should ask LWP for details on transaction fees or other custodial fees specific to their account, as these fees are not included in the annual advisory fee. LWP does not share any portion of such fees. Additionally, for any mutual funds purchased, the client may pay their proportionate share of the funds’ distribution, internal management, investment advisory and administrative fees. Such fees are not shared with LWP and are compensation to the fund manager. Clients are urged to read the mutual fund prospectus prior to investing. Mutual fund companies impose internal fees and expenses on clients. These fees are in addition to the costs associated with the investment advisory services as described above. Complete details of such internal expenses are specified and disclosed in each mutual fund company’s prospectus. Clients are strongly advised to review the prospectus(es) prior to investing in such securities. Mutual funds purchased or sold in broker-dealer accounts may generate transaction fees that would not exist if the purchase or sale were made directly with the mutual fund company. Mutual funds held in broker-dealer accounts also charge management fees. These mutual fund management fees may be more or less than the mutual fund management fees charged if the client held the mutual fund directly with the mutual fund company. Clients may purchase shares of mutual funds directly from the mutual fund issuer, its principal underwriter, or a distributor without purchasing the services of LWP or paying the advisory fee on such shares (but subject to any applicable sales charges). Certain mutual funds are offered to the public without a sales charge. In the case of mutual funds offered with a sales charge, the prevailing sales charge (as described in the mutual fund prospectus) may be more or less than the applicable advisory fee. However, clients would not receive LWP’s assistance in developing an investment strategy, selecting securities, monitoring performance of the account, and making changes as necessary. Compensation for the Sale of Securities or Other Investment Products Management personnel of LWP Wealth Advisors LLC are separately licensed as registered representatives of LPL Financial, a securities broker-dealer, and a member of the Financial Industry Regulatory Authority and the Securities Investor Protection Corporation. In this capacity as a registered representative, they will receive commission-based compensation in connection with the purchase and 6  sale of securities, including 12b-1 fees for the sale of investment company products. Compensation earned by the management personnel of LWP Wealth Advisors LLC in this capacity as a registered representative is separate from our advisory fees. This practice presents a conflict of interest because the management personnel of LWP Wealth Advisors LLC has an incentive to effect securities transactions for the purpose of generating commissions rather than solely based on your needs. However, you are under no obligation, contractually or otherwise, to purchase securities products through the management personnel of LWP Wealth Advisors LLC. Please refer to Item 12 “Brokerage Practices” of this brochure for additional information. Form ADV, Part 2A, Item 6 Performance-Based Fees and Side-By-Side Management LWP does not charge performance-based fees or participate in side-by-side management. 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. Performance-based fees are fees that are based on a share of capital gains or appreciation of the assets of a client. Our fees are calculated as described in Fees and Compensation section above and are not charged on the basis of performance of your advisory account. Form ADV, Part 2A, Item 7 Types of Clients LWP offers investment advisory services to individuals, charitable organizations and corporations. There is no minimum account size to open and maintain an advisory account. Form ADV, Part 2A, Item 8 Methods of Analysis, Investment Strategies, and Risk of Loss LWP’s methods of analysis and investment strategies incorporate the client’s needs and investment objectives, time horizon, and risk tolerance. LWP is not bound to a specific investment strategy for the management of investment portfolios, but rather consider the risk tolerance levels pre-determined gathered at the account opening, as well as on an on-going basis. We may employ hedging strategies, leverage, options, or margins, when appropriate for the client and will make adjustments for market conditions on an ongoing basis. Examples of methodologies that our investment strategies may incorporate include: Asset Allocation – Asset Allocation is a broad term used to define the process of selecting a mix of asset classes and the efficient allocation of capital to those assets by matching rates of return to a specified and quantifiable tolerance for risk. Dollar-Cost Averaging – Dollar-cost averaging is the technique of buying a fixed dollar amount of securities at regularly scheduled intervals, regardless of the price per share. This will gradually, over 7  time, decrease the average share price of the security. Dollar-cost averaging lessens the risk of investing a large amount in a single investment at the wrong time. Technical Analysis – involves studying past price patterns and trends in the financial markets to predict the direction of both the overall market and specific stocks. Long-Term Purchases – securities purchased with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. Short-Term Purchases – securities purchased with the expectation that they will be sold within a relatively short period of time, generally less than one year, to take advantage of the securities’ short-term price fluctuations. Our strategies and investments may have unique and significant tax implications. Regardless of your account size or other factors, we strongly recommend that you continuously consult with a tax professional prior to and throughout the investing of your assets. Investing in securities involves risk of loss that clients should be prepared to bear. Although we manage your portfolio with strategies and in a manner consistent with your risk tolerances, there can be no guarantee that our efforts will be successful. You should be prepared to bear the risk of loss. All investments involve the risk of loss, including (among other things) loss of principal, a reduction in earnings (including interest, dividends, and other distributions), and the loss of future earnings. These risks include market risk, interest rate risk, issuer risk, and general economic risk. Regardless of the methods of analysis or strategies suggested for your particular investment goals, you should carefully consider these risks, as they all bear risks. LWP’s primary goal for investing is to help the client maintain purchasing power over the long term. This may result in short term variability and loss of principal. Time horizon and risk tolerance are key determinates of the proper asset allocation. LWP’s approach focuses on taking appropriate risks for which clients are compensated (i.e. market risk) and seeking to limit or eliminate risks that do not provide compensation over the long term (i.e. individual stock risk or lack of portfolio risk). Below are some more specific risks of investing: Market Risk. The prices of securities in which clients invest may decline in response to certain events taking place around the world, including those directly involving the companies whose securities are owned by the client or an underlying fund; conditions affecting the general economy; overall market changes; local, regional or global political, social or economic instability; and currency, interest rate and commodity price fluctuations. Investors should have a long-term perspective and be able to tolerate potentially sharp declines in market value. Management Risk. LWP’s investment approach may fail to produce the intended results. If our perception of the performance of a specific asset class or underlying fund is not realized in the expected time frame, the overall performance of client’s portfolio may suffer. Equity Risk. 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. 8  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 Risk. 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 is likely to decrease. A nominal interest rate is the sum of a real interest rate and an expected inflation rate. Municipal Securities Risk. The value of municipal obligations can fluctuate over time, and may be affected by adverse political, legislative and tax changes, as well as by financial developments that affect the municipal issuers. Because many municipal obligations are issued to finance similar projects by municipalities (e.g., housing, healthcare, water and sewer projects, etc.), conditions in the sector related to the project can affect the overall municipal market. Payment of municipal obligations may depend on an issuer’s general unrestricted revenues, revenue generated by a specific project, the operator of the project, or government appropriation or aid. There is a greater risk if investors can look only to the revenue generated by the project. In addition, municipal bonds generally are traded in the “over-the- counter” market among dealers and other large institutional investors. From time to time, liquidity in the municipal bond market (the ability to buy and sell bonds readily) may be reduced in response to overall economic conditions and credit tightening. Investment Companies Risk. 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). 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. LWP has no control over the risks taken by the underlying funds. Artificial Intelligence and Machine Learning Risk. Certain service providers utilized by the Firm to service client accounts have artificial intelligence components. The use of artificial intelligence and machine learning includes increased risk of data inaccuracies and security vulnerabilities. Due to the rapid advancement of machine learning technologies, future risks related to artificial intelligence are unpredictable. As a measure to mitigate these risks to our clients, the Firm performs periodic due diligence of our service providers for assurance that the service providers have appropriate controls in place to protect our clients’ information and to limit data inaccuracies when artificial intelligence is used by the service provider. 9  Form ADV, Part 2A, Item 9 Disciplinary Information Loftin Wealth Partners or its Principal Executive Officers have not had any reportable disclosable events in the past ten years. Form ADV, Part 2A, Item 10 Other Financial Industry Activities and Affiliations Management personnel of LWP Wealth Advisors LLC are separately licensed as registered representatives of an unaffiliated broker-dealer, LPL Financial. These individuals, in their separate capacity, can effect securities transactions for which they will receive separate, yet customary compensation. LWP has received financial consideration from LPL Financial in connection with the transition of client custodial assets to LPL Financial, including a forgivable loan the terms of which are conditioned upon LWP maintaining its custodial relationship with LPL Financial. This arrangement creates a conflict of interest, as LWP has a financial incentive to recommend and continue using LPL Financial as custodian. Please refer to Item 14 for a full description of this arrangement and how LWP manages the resulting conflict of interest. In addition, some personnel of our firm are also licensed as independent insurance agents with various insurance agencies and can sell insurance products to you (i.e. life, health, and long-term care products) and earn commissions. Insurance commissions earned are separate and distinct from our advisory fees. This practice presents a conflict of interest because persons providing investment advice on behalf of our firm who are insurance agents have an incentive to recommend insurance products to you for the purpose of generating commissions rather than solely based on your needs. However, you are under no obligation, contractual or otherwise, to purchase insurance products through any person affiliated with our firm. While LWP and these individuals endeavor at all times to put the interest of the clients first as part of our fiduciary duty, clients should be aware that the receipt of additional compensation itself creates a conflict of interest and may affect the judgment of these individuals when making recommendations. Neither LWP nor its representatives are registered as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor. Form ADV, Part 2A, Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading LWP’s Code of Ethics includes guidelines for professional standards of conduct for our Associated Persons. Our goal is to protect client interests at all times and to demonstrate our commitment to fiduciary duties of honesty, good faith, and fair dealing. All of LWP’s Associated Persons are expected to strictly adhere to these guidelines. Persons associated with LWP are also required to report any violations to the Code of Ethics. Additionally, the firm maintains and enforces written policies reasonably designed to 10  prevent the misuse or dissemination of material, non-public information about our clients or client accounts by persons associated with our firm. LWP and its employees may buy or sell securities that are also held by clients. It is the expressed policy of the advisor that no person employed by our firm purchase or sell any security prior to the transaction being implemented for an advisory account; therefore, preventing such employees from benefiting from transactions placed on behalf of the advisory clients. The advisor may have an interest or position in a certain security, which may also be recommended to the client. As these situations may present a conflict of interest, the advisor has established the following restrictions in order to ensure its fiduciary responsibilities: 1. A director, officer or employee of the advisor shall not buy or sell a security for their personal portfolio(s) where their decision is substantially derived, in whole or part, by reason of his or her employment, unless the information is also available to the investing public. No owner/employee of LWP shall prefer their own interest to that of the client. 2. The advisor maintains a list of all securities held by the company and all directors, officers, and employees. These holdings are reviewed on a quarterly basis by the principal of the firm. 3. The advisor requires that all employees must act in accordance with all applicable Federal and State regulations governing registered investment advisors. 4. The advisor may block personal trades with those of clients but will ensure that clients are not at a disadvantage. LWP’s Code of Ethics is available to you upon request. You may obtain a copy of our Code of Ethics by contacting James Loftin at (888) 556-3846. Form ADV, Part 2A, Item 12 Brokerage Practices LWP offers a clearing platform to execute securities business for investment advisory services through primarily LPL Financial. In order for LWP to provide asset management services, we request you utilize the brokerage and custodial services of LPL Financial. LPL Financial is an independent SEC-registered broker dealer and is separate and unaffiliated with LWP. LPL Financial offers services to independently registered investment advisors which include custody of securities, trade execution and clearance and settlement of transactions. LWP receives certain practice management and technology benefits from LPL Financial through its participation in the LPL Financial Institutional program, including access to research, compliance tools, and technology platforms. These benefits are not based on the volume of client transactions directed to LPL Financial. Clients should be aware that LWP's recommendation to use LPL Financial as custodian may be influenced by these benefits. Please refer to Item 14 for disclosure of additional compensation received from LPL Financial and the conflicts of interest it creates. LWP evaluates broker dealer/custodians based on our projected AUM and the best fit for our business model. In considering which independent qualified custodian would be the best fit for LWP’s business model, we evaluate the following factors, which is not an all-inclusive list: Financial strength ➢ ➢ Reputation ➢ Reporting capabilities 11  Pricing, and ➢ Execution capabilities ➢ ➢ Types and quality of research While you are free to choose any broker-dealer or other service provider, we recommend that you establish an account with a brokerage firm with which we have an existing relationship. Such relationships may include benefits provided to our firm, including, but not limited to research, market information, and administrative services that help our firm manage your account(s). We believe that recommended broker-dealers provide quality execution services for our clients at competitive prices. Price is not the sole factor we consider in evaluating best execution. We also consider the quality of the brokerage services provided by the recommended broker-dealers, including the value of research provided, the firm’s reputation, execution capabilities, commission rates, and responsiveness to our clients and our firm. You may direct us in writing to use a particular broker-dealer to execute some or all of the transactions for your account. If you do so, you are responsible for negotiating the terms and arrangements for the account with that broker-dealer. We may not be able to negotiate commissions, obtain volume discounts, or best execution. In addition, under these circumstances a difference in commission charges may exist between the commissions charged to clients who direct us to use a particular broker or dealer and other clients who do not direct us to use a particular broker or dealer. LWP does not receive client referrals from broker-dealers in exchange for cash or other compensation, such as brokerage services or research. LWP does not have any formal soft dollar arrangements. However, LWP has received transition assistance from LPL Financial in connection with the transfer of client assets to LPL Financial as custodian. This arrangement is described in Item 14. When LWP buys or sells the same security for two or more clients (including our personal accounts), we may place concurrent orders to be executed together as a single “block” in order to facilitate orderly and efficient execution. Each client account will be charged or credited with the average price per unit. We receive no additional compensation or remuneration of any kind because we aggregate client transactions. No client is favored over any other client. If an order is not completely filled, it is allocated pro-rata based on an allocation statement prepared by LWP prior to placing the order. Because of an order’s aggregation, some clients may pay higher transaction costs, or greater spreads, or receive less favorable net prices on transactions than would otherwise be the case if the order had not been aggregated. Form ADV, Part 2A, Item 13 Review of Accounts Client accounts are reviewed at least quarterly by James Loftin, Principal Executive Officer of the firm. James Loftin reviews clients’ accounts with regards to their investment policies and risk tolerance levels. All accounts at LWP are assigned to this reviewer. All financial planning accounts are reviewed upon financial plan creation and plan delivery by James Loftin, Principal Executive Officer of the firm. There is only one level of review and that is the total review conducted to create the financial plan. 12  Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). Each client will receive at least quarterly a written report that details the clients’ account which may come from the custodian. Clients may be provided a one-time financial plan concerning their financial situation. After the presentation of the plan, there are no further reports. Clients may request additional plans or reports for a fee. Form ADV, Part 2A, Item 14 Client Referrals and Other Compensation LWP does not compensate any individual or firm for client referrals. In addition, LWP does not receive compensation for referring clients to other professional service providers. LWP received a forgivable loan from LPL Financial in connection with the transition of client custodial assets from TD Ameritrade to LPL Financial. The loan is forgiven over time provided that LWP maintains its custodial relationship with LPL Financial in accordance with the terms of the agreement. The outstanding balance of the loan decreases as forgiveness milestones are met. This arrangement creates a conflict of interest. Because a portion of the loan remains subject to repayment if LWP were to transfer client assets away from LPL Financial, LWP has a financial incentive to recommend LPL Financial as custodian and to maintain that relationship, independent of whether LPL Financial continues to represent the best custodial option for any particular client. LWP addresses this conflict by evaluating custodial arrangements based on the best interests of clients and not solely on the basis of this financial arrangement. Clients are not obligated to maintain accounts at LPL Financial and may request a transfer to another qualified custodian at any time. Form ADV, Part 2A, Item 15 Custody LWP does not have physical custody of any client funds and/or securities and does not take custody of client accounts at any time. Client funds and securities will be held with a bank, broker dealer, or other independent qualified custodian. However, by granting LWP written authorization to automatically deduct fees from client accounts, LWP is deemed to have limited custody. You will receive account statements from the independent, qualified custodian holding your funds at least quarterly. The account statement from your custodian will indicate the amount of advisory fees deducted from your account(s) each billing cycle. Clients should carefully review statements received from the custodian. LWP also sends quarterly invoices detailing the manner and amount of advisory fees to all clients. Standing Letters of Authorization Some clients may execute limited powers of attorney or other standing letters of authorization that permit the firm to transfer money from their account with the client’s independent qualified Custodian to third-parties. This authorization to direct the Custodian may be 13  deemed to cause our firm to exercise limited custody over your funds or securities and for regulatory reporting purposes, we are required to keep track of the number of clients and accounts for which we may have this ability. We do not have physical custody of any of your funds and/or securities. Your funds and securities will be held with a bank, broker-dealer, or other independent, qualified custodian. You will receive account statements from the independent, qualified custodian(s) holding your funds and securities at least quarterly. The account statements from your custodian(s) will indicate any transfers that may have taken place within your account(s) each billing period. You should carefully review account statements for accuracy. Form ADV, Part 2A, Item 16 Investment Discretion Before LWP can buy or sell securities on your behalf, you must first sign our discretionary management agreement, a limited power of attorney, and/or trading authorization forms. By choosing to do so, you may grant the firm discretion over the selection and amount of securities to be purchased or sold for your account(s) without obtaining your consent or approval prior to each transaction. Clients may impose limitations on discretionary authority for investing in certain securities or types of securities (such as a product type, specific companies, specific sectors, etc.), as well as other limitations as expressed by the client. Limitations on discretionary authority are required to be provided to the IAR in writing. Please refer to the “Advisory Business” section of this Brochure for more information on our discretionary management services. Form ADV, Part 2A, Item 17 Voting Client Securities We do not vote proxies on behalf of your advisory accounts. At your request, we may offer you advice regarding corporate actions and the exercise of your proxy voting rights. If you own shares of common stock or mutual funds, you are responsible for exercising your right to vote as a shareholder. In most cases, you will receive proxy materials directly from the account custodian. However, in the event we were to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we would forward any electronic solicitation to vote proxies. Form ADV, Part 2A, Item 18 Financial Information LWP is not required to provide financial information to our clients because we do not require or solicit the prepayment of more than $1,200 six or more months in advance. 14  Form ADV, Part 2A, Item 19 Requirements for State-Registered Advisers This section is not applicable because the firm is registered with the Securities and Exchange Commission. 15