Overview

Assets Under Management: $1.2 billion
Headquarters: ATLANTA, GA
High-Net-Worth Clients: 295
Average Client Assets: $3 million

Frequently Asked Questions

LONGVIEW WEALTH MANAGEMENT charges 1.75% on the first $0 million, 1.50% on the next $0 million, 1.25% on the next $0 million, 1.20% on the next $1 million according to their SEC Form ADV filing. See complete fee breakdown ↓

Yes. As an SEC-registered investment advisor (CRD #136214), LONGVIEW WEALTH MANAGEMENT is subject to fiduciary duty under federal law.

LONGVIEW WEALTH MANAGEMENT is headquartered in ATLANTA, GA.

LONGVIEW WEALTH MANAGEMENT serves 295 high-net-worth clients according to their SEC filing dated February 25, 2026. View client details ↓

According to their SEC Form ADV, LONGVIEW WEALTH MANAGEMENT offers financial planning, portfolio management for individuals, portfolio management for institutional clients, pension consulting services, and selection of other advisors. View all service details ↓

LONGVIEW WEALTH MANAGEMENT manages $1.2 billion in client assets according to their SEC filing dated February 25, 2026.

According to their SEC Form ADV, LONGVIEW WEALTH MANAGEMENT serves high-net-worth individuals, institutional clients, and pension and profit-sharing plans. View client details ↓

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Pension Consulting, Investment Advisor Selection

Fee Structure

Primary Fee Schedule (ADV PART II BROCHURE)

MinMaxMarginal Fee Rate
$0 $100,000 1.75%
$100,001 $250,000 1.50%
$250,001 $500,000 1.25%
$500,001 $1,000,000 1.20%
$1,000,001 and above 1.00%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $13,125 1.31%
$5 million $53,125 1.06%
$10 million $103,125 1.03%
$50 million $503,125 1.01%
$100 million $1,003,125 1.00%

Clients

Number of High-Net-Worth Clients: 295
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 69.39
Average High-Net-Worth Client Assets: $3 million
Total Client Accounts: 3,002
Discretionary Accounts: 2,999
Non-Discretionary Accounts: 3
Minimum Account Size: None

Regulatory Filings

CRD Number: 136214
Filing ID: 2060219
Last Filing Date: 2026-02-25 16:04:09

Form ADV Documents

Primary Brochure: ADV PART II BROCHURE (2026-02-25)

View Document Text
ITEM 1 – COVER PAGE SEC FORM ADV PART 2A “Brochure” LongView Wealth Management, Inc. 5605 Glenridge Drive, Suite 300 Atlanta, GA 30342 P: 404-843-3100 www.LongViewWealthManagement.com February 25, 2026 This Brochure provides information about the qualifications and business practices of LongView Wealth Management, Inc. If you have any questions about the contents of this Brochure, please contact us by phone at 404-843-3100 or send an email to jhayes@lvwm.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about LongView Wealth Management also is available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for LongView Wealth Management is 136214. Any references to LongView Wealth Management as a registered investment adviser or its related persons as registered investment advisory representatives does not imply a certain level of skill or training. LongView Wealth Management ITEM 2 - MATERIAL CHANGES 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. This Brochure contains updated information about LongView’s business since our last annual filing in March of 2025. We have provided updates on our business and enhanced disclosures regarding the following items: There have been no material changes to the firm disclosure document. LongView will further provide you with a new Brochure as necessary based on changes or new information, at any time, without charge. Currently, LongView’s Brochure may be requested by contacting Mr. John Hayes, Chief Compliance Officer at (404) 843-3100 or jhayes@lvwm.com. information about LongView is also available via the SEC’s web Additional site www.adviserinfo.sec.gov . The searchable IARD/CRD number for LongView is 136214. The SEC’s web site also provides information about any persons affiliated with LongView who are registered, or are required to be registered, as investment adviser representatives of LongView. 2 LongView Wealth Management ITEM 3 - TABLE OF CONTENTS ITEM 2 - MATERIAL CHANGES ................................................................................................ 2 ITEM 3 - TABLE OF CONTENTS................................................................................................ 3 ITEM 4 - ADVISORY BUSINESS ................................................................................................. 4 ITEM 5 - FEES AND COMPENSATION...................................................................................... 8 ITEM 6 – PERFORMANCE –BASED FEES AND SIDE BY SIDE MANAGEMENT .............. 12 ITEM 7 – TYPES OF CLIENTS.................................................................................................. 12 ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS 12 ITEM 9 - DISCIPLINARY INFORMATION.............................................................................. 15 ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ............... 15 ITEM 11 – CODE OF ETHICS, PARTICIPATION OF INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ....................................................................... 16 PROHIBITION ON USE OF INSIDER INFORMATION.......................................................... 17 ITEM 12 – BROKERAGE PRACTICES .................................................................................... 17 ITEM 13 - REVIEW OF ACCOUNTS ........................................................................................ 20 ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION....................................... 21 ITEM 15 - CUSTODY.................................................................................................................. 21 ITEM 16 - INVESTMENT DISCRETION .................................................................................. 22 ITEM 17 – VOTING CLIENT SECURITIES ............................................................................. 22 ITEM 18 – FINANCIAL INFORMATION ................................................................................. 22 3 LongView Wealth Management ITEM 4 - ADVISORY BUSINESS LongView Wealth Management, Inc. (hereinafter referred to as “LongView” or “we”) is an investment advisory firm offering a variety of advisory services customized to your individual needs. A. LongView was created in 1978 and is organized as a corporation. Larry Quinton Fisher is our CEO and Jennifer Stewart is our President. B. LongView offers the following advisory services. Each of the services is more fully described below. Initial and/or Periodic Financial Planning and Asset Allocation Services • Asset Management • • Divorce Planning Services • Analysis, Recommendation and Monitoring of Third-Party Managed Programs C. LongView tailors the advisory services it offers to you to meet your individual needs. LongView will ask for financial documents and have you complete a data gathering questionnaire which will assist LongView with obtaining information about your financial situation and history. Additionally, LongView will meet with you in person or virtually to discuss your goals and timelines which will assist LongView in providing you with the services requested and pertinent to your financial situation. Documents frequently requested will include but not limited to: • Financial Statements • Tax Records • Cash flow analysis • Other applicable financial information required by LongView in order to provide the investment advisory services requested. As of December 31, 2025, we managed approximately $1,153,580,840 of client assets under management on a discretionary basis and $188,490 on a non-discretionary basis. D. Asset Management Services LongView offers continuous and ongoing asset management services based on a client’s individual needs. LongView has arrangements with multiple broker/dealers to offer clients custodial services and enable LongView to manage client’s assets. Please refer to the disclosures in Item 12 for additional information about the relationship between LongView and the broker/dealers. Accounts are managed by LongView on a discretionary or non-discretionary basis as agreed to between the client and LongView. For the accounts managed on a discretionary basis, you will give LongView the authority to determine the securities to be purchased and sold in the account and alter the securities holdings from time to time, without prior consultation with you. Such discretionary authority will be granted in the Client Agreement executed by you and LongView. If you elect to have your accounts managed on a nondiscretionary basis, no changes will be made to the allocation of your account without prior consultation with you and your expressed agreement. LongView primarily uses open-ended mutual funds, ETF’s, stocks, and bonds. 4 LongView Wealth Management Clients are advised that transactions that occur in the account such as account reallocations and rebalancing can trigger a taxable event for the client. However, note that LongView does not provide tax advice and you are encouraged to consult a tax professional to evaluate any tax implications. E. LongView offers Advisory Services through the following programs: • LongView Wealth Management Program Wrap • LongView Wealth Management Program Non-Wrap • LongView Wealth Management Financial Planning Engagement • Divorce Planning • Third-Party Money Managers • Envestnet • Frontier LongView Wealth Management Program (Wrap) LongView uses a wrap program which for a management fee will include LongView’s charge for managing your account as well as ticket charges assessed by the custodian for transactions placed in your account. Be aware the custodian does charge other fees which will not be covered by the wrap fee. A full list of charges assessed by the custodian is available for your review provided by the custodian. Typically, a wrap program is more suitable for clients who will have more frequent trading in securities for which the custodian charges transaction fees. Custodial services are made available through Schwab Institutional a division of Charles Schwab & Co., Inc. (“Schwab”) and National Financial Services LLC or Fidelity Brokerage Services LLC (“Fidelity”), both of which are a registered broker/dealer and member SIPC. Refer to Item 12 for additional information about Schwab and Fidelity. LongView Wealth Management Program (Non-Wrap) LongView uses a non-wrap program which for a management fee will only include LongView’s charge for managing your account. Transaction fees in the form of ticket charges will be assessed by the custodian for transactions placed in your account. Be aware the custodian does charge other fees and a full list of charges assessed by the custodian is available for your review provided by the custodian. Typically, a non-wrap program is more suitable for clients who will have more less frequent trading in securities for which the custodian charges transaction fees. Custodial services are made available through Schwab Institutional a division of Charles Schwab & Co., Inc. (“Schwab”) and National Financial Services LLC or Fidelity Brokerage Services LLC (“Fidelity”), both of which are a registered broker/dealer and member SIPC. Refer to Item 12 for additional information about Schwab and Fidelity. Initial and/or Periodic Financial Planning and Asset Allocation Services Initial and/or Periodic Financial Planning Advisory Services include the initial writing and formulation of a personal financial plan. Services may be inclusive or limited, as agreed. Periodic Financial Planning Advisory Services include the design, construction, asset allocation, implementation, and monitoring of investment portfolios. Miscellaneous Services include evaluation, analysis, and recommendations concerning specific, isolated financial planning problems or investment decisions. 5 LongView Wealth Management LongView furnishes financial planning advice by way of incidental consultations. These consultations can contain advice about securities and are not included in any manner described above. Asset allocation services include the design, construction of an asset allocation and periodic monitoring of the account. If LongView or your LongView Advisory Representative is not the representative of record on the account, the client will be responsible for implementation of the designed asset allocation plan. Further, unless duplicate statements and confirmation can be sent by the account custodian to LongView it will be the client’s responsibility to provide at least quarterly statements to LongView. These services are periodic and are not meant to be considered or held out as continuous and ongoing asset management services. Advice will be provided upon the request of the client or as a result of a market event. The above services can be combined. Our advice will be based on information, documents, and risk guidelines which clients provide. During the financial planning process, LongView works with clients to define personal goals, evaluate existing financial circumstances and develop coordinated strategies to meet financial objectives. The client may, at his or her discretion, choose to implement the plan with LongView. Implementation of the plan requires LongView to work closely with the client's attorney, accountant, banker, or other trusted financial advisors. Finally, LongView can work with the client to review and update their plan on a regular basis. The Financial Plan includes written presentation of client objectives and goals, a summary of assumptions used in preparing financial analyses, a summary of significant events occurring during the planning period, a discussion addressing each of the client's objectives, and assessing his or her ability to achieve each goal, and recommendations detailing the steps the clients must take to achieve the financial objectives. Financial analyses are devised in applicable areas of tax planning, budgeting, children's education, retirement planning, insurance and disability protection, estate planning, investments and business planning. Financial planning services are based on the client’s financial situation at the time and are based on financial information disclosed by the client to LongView. Clients are advised certain assumptions are made with respect to interest and inflation rates and use of past trends and performance of the market and economy. However, past performance is in no way an indication of future performance. LongView cannot offer any guarantees or promises that client’s financial goals and objectives will be met. Further, client must continue to review any plan and update the plan based upon changes in the client’s financial situation, goals, or objectives or changes in the economy. Should client’s financial situation or investment goals or objectives changes, clients must notify LongView promptly of these changes. Once the client receives written recommendations, it is client’s decision alone to implement the recommendations, either completely, in part, or not at all. Divorce Planning (Consulting) Certain Advisory Representatives of Long View offer divorce-consulting services. Services will include but will not be limited to summary of income and expenses (pre and post-divorce), summary of present financial position (community and separate property), options regarding division of property, projected net worth (post-divorce), 6 LongView Wealth Management projected cash flow (post-divorce), recommended financial plan, expert witness regarding financial matters, all post-divorce services related to the divorce. Third-Party Managed Programs LongView and its Advisory Representative(s) provide asset allocation advice through various third-party fund management programs, such as Envestnet and Frontier. Advisory Representative will assist the client in selecting a suitable investment portfolio and asset allocation strategy that will be used by the program sponsor to properly allocate the client’s assets in the investment portfolio. Advisory Representative provide initial and ongoing client education concerning the asset allocation strategy selected by client, explain rebalancing guidelines utilized with the investment allocation strategy selected and meet with client periodically to discuss changes in client’s investment objectives and risk tolerance. The investment portfolio will be created by the program sponsor, which typically determines the funds included in the portfolio it creates, the specific asset allocations within each portfolio, and rebalances the portfolio periodically. The program sponsor will periodically change the relative allocations among funds in the portfolio. The third party will generally determine the minimum investment amount for client participation. Disclosure of the third-party manager’s minimum account requirements will be disclosed in the third- party manager’s disclosure brochure. Clients are advised that third-party managed programs can be more or less expensive than if the client obtained services directly from the third-party manager or obtained services separately. It is important to read the third-party manager’s Disclosure Brochure before entering into a third-party program. Held-Away Accounts We use a third-party platform (Pontera) to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive 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, Adviser will review the current account allocations. When deemed necessary, Adviser 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 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. General Information You are advised the investment recommendations and advice offered by LongView are not legal, tax or accounting advice. You should coordinate and discuss the impact of financial advice with your attorney and/or accountant. You are advised that it is necessary to inform LongView promptly with respect to any changes in your financial situation and investment goals and objectives. Failure to notify LongView of any such changes could result in investment recommendations not meeting your needs. Advisory Representatives recommend to clients the use of various share classes of mutual funds 7 LongView Wealth Management including no transaction fee funds. This will create conflicts of interest as the IAR will be incentivized to recommends funds which will not charge them a ticket charge for wrap accounts and is not necessarily in your best interest. Generally, clients should select the lowest cost available share class for wrap accounts. For Non-Wrap accounts a client should weigh the benefit of not paying a ticket charge with the increased cost for the share class. Clients are advised of the following: 1. Class I shares generally have lower internal expenses and no upfront fees. There may be minimums to utilize this share class. 2. No Transaction fee funds typically have higher internal expenses that can outweigh the benefits of not paying a ticket charge. Disclosure of the costs and expenses of various share classes is contained in the prospectus. Clients should read the prospectus prior to investing. The cost to the client will vary depending on the type of share class of mutual funds purchased, amount of trading, and amount of service requested by the client. Clients are advised that clients will continue to pay internal expenses of the mutual fund even after the termination of the advisory agreement. It is important to consider and evaluate the internal costs. Though internal costs are not evident on statements and confirmations, such costs and expenses should be considered along with the advisory fee you pay LongView, when determining your total cost of investing. There is no assurance that the level of experience and service each individual IAR provides is uniform. LongView clients can pay more or less for the same service due to the experience and time required to complete plan and sophistication of its Financial Planner. ITEM 5 - FEES AND COMPENSATION Asset Management Services: LongView Wealth Management Wrap and Non-Wrap Program A. Fees are negotiable and are not based on a share of capital gains or capital appreciation of the funds or any portion of the funds. Fees will vary from client-to-client and are detailed in the Client Agreement provided to the client. Fees are determined by the Investment Advisor Representative and agreed on by you the client. An IAR will use many factors to determine the fee charged to include but not limited to the complexity of the services needed, time required for completion, and the experience level of the IAR. Therefore, a client can pay more or less than another client serviced by the same or another Advisory Representative. Your Advisory Representative has an incentive in the advisory fee paid by the client since the Advisory Representative will receive a portion of the advisory fee collected by LongView. Your account balance will fluctuate throughout the quarter due to asset appreciation or depreciation or account withdrawals and deposits, however these fluctuations will not affect your billing. For accounts billed in advance billings are calculated based on the account value of the account on the last day of the prior quarter. For accounts billed in arrears billings are calculated based on the account value of the account on the last day of the quarter. Your Advisory Representative may choose to aggregate a client’s household managed accounts 8 LongView Wealth Management together. This aggregation will increase the total managed assets and the higher amount will help a client reach a breakpoint or participate in higher tiers which are generally charged a smaller fee. Management Fees are charged in one of three ways. Breakpoint fee – The fee is determined by a reducing fee schedule based on predetermined asset ranges. The fee charged will be the fee for the corresponding range the assets fall into. Tier fee – The fee is determined on a reducing schedule in which the assets are charged the value in each tier for the portion of the assets that fit into each tier. So instead of only paying one fee at the highest range the client will pay at each range as described below. The account balance is 2 million dollars. Calculated Amount for $2,000,000.00 FROM $0 $100,000.00 $250,000.00 $500,000.00 $1,000,000.00 TO $100,000 $250,000 $500,000 $1,000,000 and higher CLIENT FEE 1.75% 1.50% 1.25% 1.20% 1.00% $100,000.00 x 1.75% = $1,750.00 $150,000.00 x 1.50% = $2,250.00 $250,000.00 x 1.25% = $3,125.00 $500,000.00 x 1.20% = $6,000.00 $1,000,000.00 x 1.00% = $10,000.00 $23,125.00 = blended rate of 1.16% Flat Rate – The fee for flat rate is determined by multiplying the assets by the rate agreed upon. Actual fees are negotiable and based upon the services requested by the client, the complexity of the client’s situation, and the amount of time required to provide the services. Further, advisory fees vary based on the IAR and their experience. Therefore, clients are advised that certain Advisory Representatives of LongView charge more or less than others so the fee quoted to you as the client will be more or less than other clients. LongView can change the fee schedule upon 30-days prior written notice to you. Advisory fees will generally be collected directly from your account, provided you have given LongView written authorization. You will be provided with an account statement reflecting the deduction of the advisory fee direct from the account custodian. If the account does not contain sufficient funds to pay advisory fees, LongView has limited authority to sell or redeem securities in sufficient amounts to pay advisory fees. You may reimburse the account for advisory fees paid to LongView, except for ERISA and IRA accounts. B. In addition to the advisory fees set forth above, there may also be account maintenance fees, custodial fees, transaction fees, and retirement fees for maintaining their portfolio. LongView does not share in any portion of these fees. However, clients participating in a wrap account where the client pays one fee for asset management and transactional charges will not be assessed separate transactions charges. Instead, the client will pay one all-inclusive fee that includes LongView’s fee and LongView will pay any transaction fees. As noted elsewhere in this Brochure, this creates a conflict of interest for LongView as it will have an incentive to limit transactions in wrap fee accounts to no-transaction fee funds to reduce costs. You will pay your proportionate share of the fund’s management and administrative fees and sales charges as well as the mutual fund adviser’s fee of any mutual fund they purchase. Such advisory fees are not shared with LongView and are compensation to the fund-manager. 9 LongView Wealth Management C. Advisory fees are charged on a quarterly basis in advance or in arrears, depending on the Advisory Representative and as negotiated with the client. Quarterly periods can be on a calendar year basis or every three months starting on cycle as agreed between client and Advisory Representative. If a client relationship is established or closed during a quarterly period, the client may be charged a prorated portion of the fee for the quarter. In cases where fees are charged in advance, the initial fee will be based on the value of the account upon establishment and will be prorated based on the number of days remaining in the quarterly period. In cases where the fee is charged in arrears, the initial fee will be a prorated fee based on the number of days the account was under management and based on the value of the account as of the last business day of the quarter. Thereafter the fees will be calculated based on the value of the account on the last business day of the just completed quarterly period. A set-up fee not to exceed one percent (1%) of the initial account value may be charged. The set- up fee will be billed in full along with the first quarter fee. The set-up fee is negotiable. You can purchase the securities recommended by LongView directly or through other brokers or agents not affiliated with LongView. Termination Provisions For the above services, client may terminate LongView’s engagement within five business days following receipt of Part 2 of Form ADV and receive a full refund of all prepaid fees paid to LongView. Thereafter, client may terminate upon LongView’s receipt of client’s written notice to terminate and receive a pro rata portion of the prepaid advisory fee based upon the time remaining under the client Agreement from the date of receipt of client’s written notice to terminate to the end of the quarterly period. Clients who are paying in arrears will be charged a prorated fee for the quarter up to the date of receipt of client’s written notice to terminate. Termination Provisions For the above services, client may terminate LongView’s engagement within five business days following receipt of Part 2 of Form ADV and receive a full refund of all prepaid fees paid to LongView. Thereafter, client may terminate upon LongView’s receipt of client’s written notice to terminate and receive a pro rata portion of the prepaid advisory fee based upon the time remaining under the client Agreement from the date of receipt of client’s written notice to terminate to the end of the calendar quarter. Clients who are paying in arrears will be charged a prorated fee for the quarter up to the date of receipt of client’s written notice to terminate. Initial and/or Periodic Financial Planning and Asset Allocation Services You are advised that fees for planning and asset allocation services are strictly for planning services. Therefore, you will pay fees and/or commissions for additional services obtained such as asset management or products purchased such as securities or insurance. Fees are negotiable. Your fees will be dependent on several factors including time spent with LongView, number of meetings, complexity of your situation, amount of research, services requested and staff resources. A - Initial Financial Planning and Periodic Financial Planning Services can be charged as follows: (a) 10 LongView Wealth Management minimum fees are $1,000 for inclusive planning and $500 for limited areas of concern and (b) miscellaneous advice is up to $500 per planner hour billed monthly. Fixed fees will not exceed $15,000. Actual fees are based upon the services requested by the client, the complexity of the client’s situation, and the amount of time required to provide the services. Further, advisory fees vary based on the Advisory Representative and their experience. Therefore, clients are advised that certain Advisory Representatives of LongView charge more or less than the fee quoted to the client. A fee payment schedule will be agreed upon with the client prior to execution of the client agreement and initiation of the services. Client may be required to pay a deposit in the amount of ½ of the initial advisory fee agreed upon by client upon execution of the client agreement. At presentation of the financial plan client will be required to pay the remaining balance of the advisory fee. Advisory representative may negotiate with the client that the remaining balance may be waived if client implements recommendations with the Advisory Representative. Hourly fees are billed monthly in arrears based on time spent. B- Asset Allocation Services Asset allocation services are charged based on one of the options (Option A or Option B) disclosed below and selected by the client. The annual fee is determined and calculated as of the date of execution of the agreement. Option A – The annual fee will be determined based on a percentage of the value of the account for which monitoring, and asset allocation services are being provided and divided by four. The fee is paid quarterly in advance in equal installments. The annual fee will be adjusted each year based on the value of the account on the anniversary date, which is the date of execution of the Agreement between client and LongView or another date as agreed between LongView and the client. From To $0 $250,000.01 $500,000.01 $1,000,000.01 $250,000 $500,000 $1,000,000 and higher Maximum Client Fee 1.50% 1.25% 1.00% 1.00% Option B – Flat Fee A flat fee not to exceed $15,000. Actual fees are based upon the services requested by the client, the complexity of the client’s situation, and the amount of time required to provide the services. A flat dollar fee in lieu of a percentage fee may be proposed where the client’s assets are expected to vary greatly over the period of the agreement. A flat fee can be inclusive of periodic planning and asset allocation services. The fee will be payable every three months in advance in equal installments. Termination Provisions Client may terminate advisory services obtained from LongView, without penalty, upon written notice within five (5) business days after entering into the advisory agreement with LongView. Thereafter, client may terminate upon LongView’s receipt of client’s written notice to terminate and receive a pro- rata portion of the advisory fee based upon the time remaining under the Client 11 LongView Wealth Management Agreement. Third Party Managed Programs LongView is compensated for its services as it relates to the Third-Party Managed Programs as follows: Details of the fees, billing details and additional information about the program are disclosed in the Form ADV Part 2A of the Third Party. Clients are encouraged to read these disclosures carefully prior to entering into an advisory agreement. Divorce Planning (Consulting) Client agrees to pay LongView a retainer upon the execution of the Divorce Planning Services Agreement. The retainer will be applied to the full and final fee incurred by the client. Generally, the retainer is $2,500. Compensation to LongView will be at a rate up to four hundred ($400) dollars per hour for Advisory Representative’s services and one hundred fifty ($150) dollars per hour for administrative time. Hourly fees are negotiable. The fee includes any and all time spent by Advisory Representative related to his or her divorce consultation services. Client will be billed monthly or quarterly at LongView’s discretion commencing 30 days after the execution of the Divorce Planning Services Agreement and/or payment of the retainer described above. Clients have the option to facilitate payment by credit card. Any payments not received by LongView within 30 days of billing will accrue interest at a rate of 12% per year. Client will also be responsible for all reasonable costs associated with LongView’s and Advisory Representative’s representation. The term of this Agreement will be for an initial period of one year. In the event, neither party gives the other written notice within sixty (60) days of the expiration of said initial one year term, the Agreement will be renewed for subsequent one year periods on the same terms. Client will be responsible for all time spent by LongView on the provision of the services. Any refund of prepaid fees will be calculated based on time spent multiplied by the hourly rate subtracted from the retainer. ITEM 6 – PERFORMANCE –BASED FEES AND SIDE BY SIDE MANAGEMENT This section is not applicable to LongView since LongView does not charge performance-based fees. ITEM 7 – TYPES OF CLIENTS LongView’s services are geared toward individuals, including high net worth (i.e. clients with a net worth of $1,000,000), pension and profit-sharing plans, and corporations or other businesses. There is no required minimum for clients. ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS A. LongView conducts economic, fundamental and technical market analysis with the goal to determine the market trends and uncover investment opportunities. Fundamental analysis generally involves assessing a public company’s or security’s value based on factors such as sales, assets, markets, management, products and services, earnings, and financial structure. 12 LongView Wealth Management Technical analysis generally involves studying trends and movements in a security’s price, trading volume, and other market-related factors in an attempt to discern patterns. LongView uses various research methods in conducting the analysis. It may use, among other methods, review, study, and analysis of public company filings and company-sponsored information such as press releases, presentations, product descriptions; attend meetings with public company executives at industry conferences; conduct research on the target company’s customers, suppliers, competitors, and partners; analysis of historical company and industry financial data and others. B. You are advised that investing in securities involves risk of loss, including the loss of principal. Therefore, your participation in any of the management programs offered by LongView will require you to be prepared to bear the risk of loss and fluctuating performance. LongView does not represent, warrant or imply that the services or methods of analysis used by LongView can or will predict future results, successfully identify market tops or bottoms, or insulate you from losses due to major market corrections or crashes. Past performance is no indication of future performance. No guarantees can be offered that your goals or objectives will be achieved. Further, no promises or assumptions can be made that the advisory services offered by LongView will provide a better return than other investment strategies. All investment strategies have certain risks that are borne by the clients. LongView’s investment approach keeps the risk of loss in mind. The following is intended to provide the client with a summary of certain investment risks they may face, however, note that this list is not exhaustive: 1. 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. 2. Strategy Risk: The adviser’s investment strategies and/or investment techniques may not work as intended. 3. Regulatory Risk: Legislative changes or court rulings may impact the value of investments, or the securities’ claim on the issuer’s assets and finances. 4. Inflation: Inflation may erode the buying-power of your investment portfolio, even if the dollar value of your investments remains the same. 5. Cybersecurity Risks. These risks may include deliberate attacks or unintentional events and are not limited to gaining unauthorized access to systems, and misappropriating assets or sensitive information, such as personal identifiable information, corrupting data, or causing operational disruption, including the denial-of-service attacks on websites. Cybersecurity failures or breaches have the ability to cause disruptions and impact business operations, potentially resulting in financial losses, the inability to transact business, violations of applicable privacy and other laws. 6. Risk Associated with Specific Types of Securities. As noted, LongView primarily uses mutual funds, but may also use stocks, bonds and ETFs. 13 LongView Wealth Management a. Mutual Funds and ETFs. When investing in an ETF or mutual fund, you will bear additional expenses based on your pro rata share of the ETF’s or mutual fund’s operating expenses. When a mutual fund is not fully invested and maintains a portion of its portfolio in cash or cash equivalents, there is a risk that the market will begin to rise and cause the mutual fund to miss capturing the full effect of changing market conditions. Some mutual funds may use leverage as part of their investment strategy. Using leverage can magnify a mutual fund’s potential for gain or loss and, therefore, amplify the effects of market volatility on a mutual fund’s share price. A mutual fund may be subject to the risk that its assets are invested in a particular sector or group of sectors in the economy, and as a result, the value of the mutual fund may be adversely impacted by events or developments in a sector or group of sectors. ETFs are subject to market risk, including the possible loss of principal. ETFs trade like a stock and the value of the ETF will fluctuate with the value of the underlying securities. ETFs at times trade for more or less than their net asset value. ETFs will have underlying investment strategy risks consistent with the underlying investments in the ETFs’ portfolios. The types of investments held in ETFs may include but are not limited to equities, commodities, bonds, real estate and international securities or currencies. Due to their narrow focus, sector-based investments typically exhibit greater volatility. There are special considerations associated with international investing, including the risk of currency fluctuations and political and economic events. Investing in emerging markets may involve greater risk and volatility than investing in more developed countries. When investing in real estate companies, property values can fall due to environmental, economic, or other reasons, and changes in interest rates can negatively impact the performance. The risk of loss in trading commodities and futures can be substantial. The high degree of leverage that is often obtainable in commodity trading can work either for or against the performance of this type of investment. Common Stocks. The risks of investing in common stocks include: (i) stock market risk, which is the risk that stock prices overall will decline (stock markets tend to move in cycles, with periods of rising prices and periods of falling prices); (ii) Sector risk, which is the risk that significant problems will affect a particular sector, or that returns from that sector will trail returns from the overall stock market (daily fluctuations in specific market sectors are often more extreme than fluctuations in the overall market; and (iii) Difficulty in identifying undervalued stocks (there are no assurances that such opportunities will be successfully recognized or acquired). 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. Epidemics, Pandemics, Outbreaks of Disease and Public Health Issues. Our business activities could be materially adversely affected by pandemics, epidemics and outbreaks of disease in Asia, Europe, North 14 LongView Wealth Management America and/or globally or regionally, such as COVID-19, Ebola, H1N1 flu, H7N9 flu, H5N1 flu, Severe Acute Respiratory Syndrome (SARS), and/or other epidemics, pandemics, outbreaks of disease, viruses and/or public health issues. Specifically, COVID-19 has spread (and is currently spreading) rapidly around the world since its initial emergence in China in December 2019 and has severely negatively affected (and may continue to materially adversely affect) the global economy and equity markets (including, in particular, equity markets in Asia, Europe and the United States). Although the long-term effects or consequences of COVID-19 and/or other epidemics, pandemics and outbreaks of disease cannot currently be predicted, previous occurrences of other pandemics, epidemics and other outbreaks of disease, such as H5N1 flu, H1N1 flu, SARS and the Spanish flu, had a material adverse effect on the economies and markets of those countries and regions in which they were most prevalent. Any occurrence or recurrence (or continued spread) of an outbreak of any kind of epidemic, communicable disease or virus or major public health issue could cause a slowdown in the levels of economic activity generally (or cause the global economy to enter into a recession or depression), which would adversely affect the business, financial condition and operations of the Adviser. Should these or other major public health issues, including pandemics, arise or spread farther (or continue to spread or materially impact the day to day lives of persons around the globe), the Adviser could be adversely affected by more stringent travel restrictions, additional limitations on the Adviser’s operations or business and/or governmental actions limiting the movement of people between regions and other activities or operations (or to otherwise stop the spread or continued spread of any disease or outbreak). ITEM 9 - DISCIPLINARY INFORMATION Neither LongView nor any of its supervised persons have been the subject of any legal or disciplinary events that would be material to an evaluation of LongView or the integrity of LongView’s management. ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS A. LongView’s investment advisor representatives may also be registered representatives of M.S. Howells & Co., a registered broker/dealer, and Member of FINRA/SIPC. Clients are not obligated to purchase or sell securities through the investment advisor representatives in these separate capacities. However, if clients choose to implement the advice provided by Advisor through its investment advisor representatives in their separate capacities as registered representatives, M.S. Howells & Co. will be used, and commissions will be earned in addition to any fees paid for advisory services. B – C. LongView is an insurance agency and offers various insurance products. Should a client participate in insurance products or services through LongView, commissions will be earned. Clients are under no obligation to purchase insurance products or services through LongView. The products through LongView may be more or less expensive than those products offered through other insurance companies. LongView attempts to mitigate the conflicts of interest with the potential receipt of commissions if recommendations are implemented by developing and implementing compliance policies and procedures, including the Code of Ethics described below, supervising and monitoring the Advisory Representatives’ activities to ensure compliance with the applicable laws and LongView’s policies. Further, you are encouraged to consult other professionals and may implement recommendations through financial professionals. Furthermore, if your Investment 15 LongView Wealth Management Advisor Representative is a registered representative with M.S. Howells & Co., Registered Representatives are subject to a supervisory structure at M.S. Howells & Co. for its securities business. LongView and its management persons are not actively engaged in any other business. D. As stated under Item 4, Advisory Business above, LongView recommends other investment advisers (i.e. third-party managers) and will receive a portion of the fee charged to you by the investment adviser or will charge a fee in addition to the third-party managers. Since LongView has an interest in the compensation this is considered a material conflict of interest. LongView selects third party managers based on several criteria including cost, type of management, past history, ability to meet a need and provide a unique service. Since the fee charged to you is based on the value of your portfolio, all parties have an incentive to work toward performance goals and objectives. Consequently, if the third-party manager does not adequately manage your account and the value of your portfolio goes down, so does the third-party manager’s and LongView’s compensation. ITEM 11 – CODE OF ETHICS, PARTICIPATION OF INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Code of Ethics A. LongView has a fiduciary duty to you to act in your best interest and always place your interests first and foremost. LongView takes its compliance and regulatory obligations seriously and requires all staff to comply with such rules and regulations as well as LongView’s policies and procedures. Further, LongView strives to handle your non-public information in such a way to protect information from falling into hands that have no business reason to know such information and provides you with LongView’s Privacy Policy. As such, LongView maintains a code of ethics for its Advisory Representatives, supervised persons and staff (the “Code of Ethics”). The Code of Ethics contains provisions for standards of business conduct that are designed to uphold compliance with applicable laws and regulations; maintain integrity, honesty, loyalty, and good faith; prevent improper conduct, eliminate or reduce conflicts of interest. The Code prohibits, limits, restricts, or avoids insider trading, improper gifts, outside employment, political contributions, and self-dealing... A copy of our Code of Ethics will be provided to you upon request. B. Neither LongView nor its advisory personnel recommend to clients or buys or sells for client accounts any securities in which we have a material financial interest. C. LongView and its advisory personnel buy or sell securities identical to those securities recommended to you. Therefore, LongView and/or its advisory personnel have an interest or position in certain securities that are also recommended and bought or sold to you. LongView and its advisory personnel will not put their interests before your interest. LongView and its advisory personnel may not trade ahead of you or trade in such a way to obtain a better price for themselves than for you or other clients except when determined to be a de minimus amount. LongView uses $25.00 will be used a threshold Longview has determined that All advisory personnel is required to provide LongView with their and their immediate families’ 16 LongView Wealth Management annul holdings reports and quarterly transactions reports which are reviewed by LongView to ensure compliance with the applicable laws and regulations and LongView’s personal trading policies and procedures. You have the right to decline any investment recommendation. LongView and its advisory personnel are required to conduct their securities and investment advisory business in accordance with all applicable Federal and state securities regulations. Prohibition on Use of Insider Information LongView has also adopted policies and procedures to prevent the misuse of “insider” information (i.e. material n, non-public information). A copy of such policies and procedures is available to any person upon request. ITEM 12 – BROKERAGE PRACTICES Brokerage and custodial services are made available through Fidelity Brokerage Services LLC or Charles Schwab & Co., Inc. (Schwab), a registered broker-dealer, member SIPC. Each option has unique benefits and conflicts in which your IAR will explain fully. LongView is independently owned and operated and not affiliated with Schwab or Fidelity. Longview does not maintain custody of your assets [that we manage/on which we advise], although we may be deemed to have custody of your assets if you give us authority to withdraw assets from your account (see Item 15—Custody, below). Your assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. We recommend that our clients use either Fidelity or Charles Schwab & Co., Inc. (Schwab), a registered broker-dealer, member SIPC, as the qualified custodian. Fidelity or Schwab will hold your assets in a brokerage account and buy and sell securities when [we/you] instruct them to. While we [recommend that you use Fidelity or Schwab as custodian/broker, you will decide whether to do so and will open your account by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. We do not open the account for you, although we may assist you in doing so. [If you do not wish to place your assets with Fidelity or Schwab, then we cannot manage your account.] [Not all advisors require their clients to use a particular broker-dealer or other custodian selected by the advisor.] Even though your account is maintained at Cambridge or Schwab, and we anticipate that most trades will be executed through that broker they select, we can still use other brokers to execute trades for your account as described below (see “Your brokerage and custody costs”). How we select brokers/custodians When we recommend a custodian/broker, to hold your assets and execute transactions that are advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: separate fee for custody) • Combination of transaction execution services and asset custody services (generally without a • • Capability to execute, clear, and settle trades (buy and sell securities for your account) • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, 17 LongView Wealth Management bill payment, etc.) • Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.) • Availability of investment research and tools that assist us in making investment decisions • Quality of services • Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices • Reputation, financial strength, security and stability • Prior service to us and our clients • Services delivered or paid for by Schwab • Availability of other products and services that benefit us, as discussed below (see “Products and services available to us from Schwab”) Your brokerage and custody costs Schwab: If Schwab is selected by the client, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. Certain trades (for example, stocks and ETFs) do not incur Schwab commissions or transaction fees. Schwab is also compensated by earning interest on the uninvested cash in your account in Schwab’s Cash Features Program. For some Envestnet accounts, Schwab charges you a percentage of the dollar amount of assets in the account in lieu of commissions. Schwab’s commission rates [and] asset-based fees applicable to our client accounts were negotiated based on the total dollar amount of assets in accounts at Schwab. This commitment benefits you because the overall [commission rates [and] asset-based fees] you pay are lower than they would be otherwise. In addition to [commissions [and] asset-based fees], Schwab charges you a flat dollar amount as a “prime broker” or “trade away” fee for each trade that we have executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into your Schwab account. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. Because of this, in order to minimize your trading costs, we have Schwab execute most trades for your account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through Schwab, we have determined that having Schwab execute most trades is consistent with our duty to seek “best execution” of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see “How we select brokers/custodians above”). By using another broker or dealer you may pay lower transaction costs. Products and services available to us from Schwab (Schwab Advisor Services) is Schwab’s business serving independent investment advisory firms like us. They provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to Schwab retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis (we don’t have to request them) and at no charge to us. Following is a more detailed description of Schwab’s support services: Services that benefit you. Schwab’s institutional brokerage services include access to a broad range of 18 LongView Wealth Management investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Services that do not directly benefit you. Schwab also makes available to us other products and services that benefit us but do not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts and operating our firm. They include investment research, both Schwab’s own and that of third parties. We use this research to service all or a substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients’ accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only us. Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and compliance related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab also discounts or waives its fees for some of these services or pays all or a part of a third party’s fees. Schwab also provides us with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with Schwab, we would be required to pay for those services from our own resources. LongView mitigates the conflicts of interest resulting from receiving these benefits by periodically reviewing other options for custody and trade execution cost for our clients. Longview does this by reviewing the cost for our clients as a whole and does not make any representation for any specific client or account. The availability of these services from Schwab benefits us because we do not have to produce or purchase them. We don’t have to pay for Schwab’s services. Schwab has also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on our behalf once the value of our clients’ assets in accounts at Schwab reaches certain thresholds. These services are not contingent upon us committing any specific amount of business to Schwab in trading commissions or assets in custody. 19 LongView Wealth Management The fact that we receive these benefits from Schwab is an incentive for us to recommend the use of Schwab rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. In some cases, the services that Schwab pays for are provided by affiliate of ours or by another party that has some pecuniary, financial or other interests in us (or in which we have such an interest). This creates an additional conflict of interest. We believe, however, that taken in the aggregate our recommendation of Schwab as custodian and broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services (see “How we select brokers/ custodians”) and Schwab’s services that benefit only us. Aggregated or Block Trade Policy Due to the individual management of client accounts, we do not aggregate the purchase or sale of securities for various client accounts. Generally, this will not affect the price a client obtains since LongView’s business is primarily conducted in mutual funds and transactions where block trading has no impact. However, to the degree a client's account contains securities which are purchased and sold in an auctionable market the lack of block trading could affect the price the client receives. Therefore, clients could pay as a result of LongView generally not participating in block transactions. ITEM 13 - REVIEW OF ACCOUNTS A. If you are participating in the Asset Managements and Third Party Managed Programs you will be invited to participate in a review not less than at least annually or as agreed by you and your Advisory Representative. You may request more frequent reviews and may set thresholds for triggering events that would cause a review to take place. Your Advisory Representative will monitor for changes or shifts in the economy, changes to the management and structure of a mutual fund or company in which your assets are invested, and market shifts and corrections. Periodic Financial Planning and Asset Allocation Services reviews will be at a frequency as agreed to between you and your Advisory Representative. You will be invited to participate in a review not less than annually. All other Planning Services will not receive regular reviews. However, the time and frequency of the reviews is solely your decision. Other than the initial plan or analysis, there will be no other reports issued. The Advisory Representative selected by the client will conduct the review. B. You must notify your Advisory Representative promptly of any changes to your financial goals, objectives or financial situation as such changes may require him review the portfolio allocation and make recommendations for changes. C. Clients participating in managed account programs will be provided statements at least quarterly directly from the account custodian. Additionally, you will receive confirmations of all transactions occurring directly from the account custodian. You may request additional account summary reports from LongView at any time. You should compare any report produced by LongView with statements received from the account custodian. Should there be any discrepancy the account custodian’s report will prevail. 20 LongView Wealth Management ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION Investment product vendors recommended by LongView can provide monetary and non-monetary assistance with client events, provide educational tools and resources. LongView does not select products as a result of any monetary or non-monetary assistance. LongView’s due diligence of a product does not take into consideration any assistance it may receive. However, the receipt of any form of compensation, either directly or indirectly, is considered a conflict of interest. We also, receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab. In addition, Schwab has also agreed to pay for certain products and services for which we would otherwise have to pay once the value of our clients’ assets in accounts at Schwab reaches a certain size. You do not pay more for assets maintained at Schwab as a result of these arrangements. However, we benefit from the arrangement because the cost of these services would otherwise be borne directly by us. You should consider these conflicts of interest when selecting a custodian. The products and services provided by Schwab, how they benefit us, and the related conflicts of interest are described above. LongView mitigates this conflict of interest by supervising the activities of the Advisory Representatives, reviewing the investment recommendations provided to the clients, implementing policies and procedures, including the Code of Ethics. We also encourage you to discuss any recommendations provided by your Advisory Representative with another financial professional if you have any concerns about the appropriateness of the recommendation based on your financial situation. Our firm may engage in promoter arrangements for client referrals. These individual promoters offer our services to the public. The Firm pays a referral fee to the promoter based on a portion of the management fees charged by the Firm and memorialized in a written agreement (“Promoter Agreement”). In all cases, the Firm will comply with the cash solicitation rules established by the SEC, state regulators and the client disclosure requirements. If a referred prospective client enters into an investment advisory agreement with the Firm, a referral fee is paid to the referring party. The referral relationship will not result in clients being charged any fees over and above the normal advisory fees charged for the advisory services provided. The Firm will pay the promoter their share of the total fee. The Promoter Agreement requires that the promoter be appropriately registered under federal and state securities laws where applicable. Clients receive all related agreements and disclosures prior to or at the time of entering into an Investment Advisory Agreement with the Firm. ITEM 15 - CUSTODY All client accounts are held at qualified custodians. LongView does not take physical custody of your funds or securities. LongView may be deemed to have constructive custody if a client has a standing letter of authorization (SLOA) to transfer funds or securities to a third party and LongView has the ability to direct transfers, change the amount, and/or the timing of the transfer. Under the applicable regulations, we are deemed to have custody of your assets if, for example, you authorize us to instruct your account custodian to deduct our advisory fees directly from your account or if you grant us authority to move your money to another person’s account. Your custodian maintains physical custody of your assets. You will receive account statements directly from your account custodian at least quarterly. They will be sent to the email or postal mailing address you provided. You should carefully review those statements promptly when you receive them. Standing Letters of Authorization 21 LongView Wealth Management 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 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. ITEM 16 - INVESTMENT DISCRETION You may grant LongView authorization to manage your account on a discretionary basis. Discretionary authority will give LongView authority to buy, sell, exchange, convert securities in your managed accounts. You will grant such authority to LongView by execution of the client agreement. You may terminate discretionary authorization at any time by providing a written notice to LongView. Additionally, you are advised that: 1) You may set parameters with respect to when account should be rebalanced and set trading restrictions or limitations. 2) Your written consent is required to establish any mutual fund, variable annuity, or brokerage account. 3) LongView will not have the ability to withdraw your funds or securities from the account with the exception of the deduction of LongView’s advisory fees from the account, or if you have authorized automatic deductions. ITEM 17 – VOTING CLIENT SECURITIES LongView does not vote your securities. Unless you suppress proxies, securities proxies will be sent directly to you by the account custodian or transfer agent. You may contact LongView if you have questions on how to vote the proxies, however, you will be the one to make and execute the voting decision. ITEM 18 – FINANCIAL INFORMATION LongView has discretionary authority or custody of Client funds or securities. There is no financial condition that is reasonably likely to occur that would impair LongView’s ability to meet contractual commitments to Clients. LongView has not been the subject of a bankruptcy petition during the past ten years. 22

Additional Brochure: APPENDIX 1 WRAP BROCHURE (2026-02-25)

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LongView Wealth Management Item 1 – Cover Page FORM ADV PART 2A “APPENDIX 1” LongView Wealth Management 5605 Glenridge Drive Suite 300 Atlanta, GA 30342 P: 404-843-3100 www.LongViewWealthManagement.com www.LongViewAtlanta.com February 25, 2026 This wrap fee program Appendix 1 provides information about the qualifications and business practices of LongView Wealth Management. If you have any questions about the contents of this Appendix 1, please contact us at 404-843-3100 and/or jhayes@lvwm.com. The information in this Appendix 1 has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about LongView Wealth Management also is available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for LongView Wealth Management is 136214. Any references to LongView Wealth Management as a registered investment adviser or its related persons as registered investment advisory representatives does not imply a certain level of skill or training. 1 LongView Wealth Management Item 2 - MATERIAL CHANGES We have not made any material changes to the brochure; however, we encourage you to read the Appendix 1 in its entirety. The date of the last annual update of the Appendix 1 was March 2025. In the past, we have offered or delivered information about our qualifications and business practices to clients on at least an annual basis. Pursuant to new SEC Rules, we will ensure that you receive a summary of any material changes to this and subsequent Appendix 1 within 120 days of the close of our fiscal year, which is December 31st. We may further provide other ongoing disclosure information about material changes as necessary. LongView will further provide you with a new Appendix 1 as necessary based on changes or new information, at any time, without charge. Currently, LongView’s Appendix 1 may be requested by contacting Mr. John Hayes, Chief Compliance Officer at (404) 843-3100 or jhayes@lvwm.com. Additional information about LongView is also available via the SEC’s web site www.adviserinfo.sec.gov. The searchable IARD/CRD number for LongView is 136214. The SEC’s web site also provides information about any persons affiliated with LongView who are registered, or are required to be registered, as investment adviser representatives of LongView. 2 LongView Wealth Management Item 3 - TABLE OF CONTENTS Item 1 – COVER PAGE ............................................................................................. Cover Page Item 2 - MATERIAL CHANGES .................................................................................................... 2 Item 3 - TABLE OF CONTENTS .................................................................................................... 3 Item 4 – SERVICES, FEES AND COMPENSATION ....................................................................... 4 LongView Wealth Management Program ............................................................................................ 4 Fees and Compensation .................................................................................................................... 4 General Information ......................................................................................................................... 7 IRA Rollover Considerations ............................................................................................................. 8 Item 5 – ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ................................................ 9 Item 6 – PORTFOLIO MANAGER SELECTION AND EVALUATION ........................................... 9 Item 7 – CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS ........................... 11 Item 8 – CLIENT CONTACT WITH PORTFOLIO MANAGERS .................................................. 11 Item 9 – ADDITIONAL INFORMATION ..................................................................................... 11 Item 10 - REQUIREMENTS FOR STATE REGISTERED ADVISERS ........................................... 14 LongView Wealth Management Item 4 – SERVICES, FEES AND COMPENSATION A. Wrap Programs Wrap accounts are managed by LongView on a discretionary or non-discretionary basis as agreed to between the client and the Advisory Representative. Accounts managed on a discretionary basis will give LongView the authority to determine the securities to be purchased and sold in the account and alter the securities holdings from time to time, without prior consultation with you. Discretionary authority will be granted by you to LongView by execution of the Client Agreement. If you elect to have your accounts managed on a nondiscretionary basis, no changes will be made to the allocation of your account without prior consultation with you and your expressed agreement. The LongView Wealth Management Program (Wrap) is offered as a wrap program. A wrap program is where the client will pay one fee and the fee will cover LongView’s advisory fee and any transaction charges. Typically, a wrap program is more suitable for clients who will have more frequent trading and in securities for which the custodian charges transaction fees. In a wrap program Longview has a conflict of interest to use securities for which the account custodian waives transaction fees. Transactions in the account, account reallocations and rebalancing may trigger a taxable event for the client, with the exception of qualified retirement accounts. LongView Wealth Management Program (Wrap) LongView provides asset management services on a continuous and ongoing basis based on the individual needs of the client. Custodial services are made available through Schwab Advisor Services division of Charles Schwab & Co., Inc. (“Schwab”), and Fidelity Brokerage Services LLC (“Fidelity”) both are registered broker/dealers, member SIPC. LongView is independently owned and operated and not affiliated with Fidelity or Schwab. Schwab and Fidelity generally do not charge you separately for custody services but are compensated by charging LongView a ticket charge or a fee for executing orders in your account. In addition, they may charge you other fees which will be disclosed to you in their fee agreement. We encourage to review your fee agreements with the custodian and if you have any questions consult with your Investment Advisor Representative. We have determined that having your custodian execute most trades is consistent with our duty to seek “best execution” of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. Fees and Compensation Fees are negotiable and are not based on a share of capital gains upon or capital appreciation of the funds or any portion of the funds. Fees vary from client-to-client and are detailed on the Client Agreement provided to the client. Fees vary based on the complexity of the services, number of meetings, and the Advisory Representative. You may make additions to the Account or withdrawals from the Account, provided the Account continues to meet minimum account size requirements. No fee adjustments will be made for Account appreciation or depreciation. No fee adjustments will be made for additional deposits to or partial withdrawals from the client’s portfolio during a period. Portfolio is defined as all accounts of a client LongView Wealth Management under management. Therefore, if a client opens a new account under management or closes an account under management, there will be no fee adjustment during the quarter. Advisory Representatives can choose to aggregate all of a client’s managed accounts together to determine the fee breakpoint based on the schedule. Thus, all accounts will pay the same fee. Alternatively, Advisory Representatives can choose to charge a fee based on the value of each account under management. Therefore, clients may pay a different fee on each account based on the account value. LongView may change the fee schedule upon 30-days prior written notice to you. Wrap Program Fees* FROM TO MAXIMUM CLIENT FEE $0 $100,000 $100,000.01 $250,000 $250,000.01 $500,000 $500,000.01 $1,000,000 $1,000,000.01 and higher 1.75% 1.50% 1.25% 1.20% 1.00% *Fees may be a flat fee based on the value of the client’s managed portfolio or per account size or may be tiered. Clients on a tiered fee schedule will pay a fee based on each level outlined above (e.g. a $1,000,000 account will pay up to 1.75% on the first $100,000, 1.50% on the next $150,000, 1.25% on the next $250,000 and 1.20% on the remaining $500,000). Advisory fees will generally be collected directly from your account, provided you have given LongView written authorization. You will be provided with an account statement reflecting the deduction of the advisory fee direct from the account custodian. If the Account does not contain sufficient funds to pay advisory fees, LongView has limited authority to sell or redeem securities in sufficient amounts to pay advisory fees. You may reimburse the account for advisory fees paid to LongView, except for ERISA and IRA accounts. Advisory fees are charged on a quarterly basis in advance or in arrears, depending on the Advisory Representative and as negotiated with the client. Quarterly periods may be on a calendar year basis or every three months starting on cycle as agreed between client and advisory representative. Fees for partial quarters (i.e. accounts established or closed during a quarter period) will be charged a prorated portion of the fee for the quarterly period. In cases where fees are charged in advance, the initial fee will be based on the value of the account upon establishment and will be prorated based on the number of days remaining in the quarterly period. In cases where the fee is charged in arrears, the initial fee will be a prorated fee based on the number of days the account was under management and based on the value of the account as of the last business day of the quarterly period. Thereafter the fees will be calculated based on the value of the account on the last business day of the just completed quarterly period. A set-up fee not to exceed one percent (1%) of the initial account value may be charged. The set-up fee will be billed in full along with the first quarter fee. The set-up fee is negotiable. LongView Wealth Management Some Advisory Representatives of LongView are dually registered representatives of M.S. Howells & Co., a registered broker/dealer, member of the Financial Regulatory Association (FINRA) and SIPC. As Registered Representatives our Advisory Representatives will earn a commission on products sold through M.S. Howells & Co. so there is a conflict of interest to recommend products that pay a commission. You can purchase the securities recommended by LongView directly or through other brokers or agents not affiliated with LongView. Termination Provisions Client may terminate LongView’s engagement within five business days of execution of the advisory agreement and receive a full refund of all prepaid fees paid to LongView. Thereafter, client may terminate upon LongView’s receipt of client’s written notice to terminate and receive a pro rata portion of the prepaid advisory fee based upon the time remaining under the Client Agreement from the date of receipt of client’s written notice to terminate to the end of the calendar quarter. Clients who are paying in arrears will be charged a prorated fee for the quarter up to the date of receipt of client’s written notice to terminate. B. Wrap programs can cost the client more or less than if the client purchased advisory and execution services separately. If services are purchased separately, it is possible the advisory fee would be less and transaction charges could be controlled or managed based on the frequency of trading and the types of securities purchased (i.e. use of no transaction fee funds). Actively traded accounts are more suitable for a wrap program, depending on the number of no transaction fee funds utilized. Clients are advised that typically a wrap program is more expensive since LongView will charge a higher fee to cover any transaction expenses. Further, there is an incentive for LongView to limit transactions to no transaction fee funds in an effort to reduce LongView’s costs. This is considered a conflict of interest for LongView to cause a client to participate in a wrap program if trading will be infrequent or if a number of no transaction fee funds will be utilized since LongView will be able to retain a larger portion of the management fee since no fees will need to be allocated to trading costs by LongView. Therefore, there is an incentive for LongView to limit transactions to no-transaction fee funds in an effort to reduce LongView’s costs. Clients are advised LongView has several Advisory Representatives who are independent contractors. The Advisory Representatives may not charge an advisory fee in excess of the fee schedule disclosed above. However, each Advisory Representative determines the fee to the client. Therefore, depending on the Advisory Representative selected by the client, the client can pay more or less than another client serviced by another Advisory Representative. C. In addition to the advisory fees set forth above, client can be assessed account maintenance fees, custodial fees, and retirement fees for maintaining their portfolio. LongView does not share in any portion of these fees. Further, there is an incentive for LongView to limit transactions to no transaction fee funds in an effort to reduce LongView’s costs. Wrap accounts will be charged transaction fees for any unsolicited transaction (i.e. transactions requested by the client). Additionally, for trades executed away from the custodian, the client will be charged and responsible for any fees associated with trading the securities away and/or delivering the securities into the client’s account. LongView Wealth Management You will pay your proportionate share of the fund’s management and administrative fees and sales charges as well as the mutual fund adviser’s fee of any mutual fund they purchase. Such advisory fees are not shared with LongView and are compensation to the fund-manager. Fees not included in the advisory fee are charges imposed directly by a mutual fund, index fund, or exchange traded fund which are disclosed in the prospectus (i.e., fund management fees and other fund expenses), mark-ups and mark-downs, spreads paid to market makers, fees for trades executed away from custodian, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. D. Your Advisory Representative has an incentive in the advisory fee paid by the client since the Advisory Representative will receive a portion of the advisory fee collected by LongView. The amount of compensation paid to the Advisory Representative is not more or less than if your Advisory Representative selected another investment option. General Information You are advised the investment recommendations and advice offered by LongView are not legal, tax or accounting advice. You should coordinate and discuss the impact of financial advice with your attorney and/or accountant. You are advised that it is necessary to inform LongView promptly with respect to any changes in your financial situation and investment goals and objectives. Failure to notify LongView of any such changes could result in investment recommendations not meeting your needs. Advisory Representatives recommend to clients the use of various share classes of mutual funds including no transaction fee funds. This will create conflicts of interest as the IAR will be incentivized to recommends funds which will not charge them a ticket charge for wrap accounts and is not necessarily in your best interest. Generally, clients should select the lowest cost available share class for wrap accounts. For Non-Wrap accounts a client should weigh the benefit of not paying a ticket charge with the increased cost for the share class. Class I shares generally have lower internal expenses and no upfront fees. There may be Clients are advised of the following: 1. minimums to utilize this share class. 2. No Transaction fee funds typically have higher internal expenses that can outweigh the benefits of not paying a ticket charge. Disclosure of the costs and expenses of various share classes is contained in the prospectus. Clients should read the prospectus prior to investing. The cost to the client will vary depending on the type of share class of mutual funds purchased, amount of trading, and amount of service requested by the client. Clients are advised that clients will continue to pay internal expenses of the mutual fund even after the termination of the advisory agreement. It is important to consider and evaluate the internal costs. Though internal costs are not evident on statements and confirmations, such costs and expenses should be considered along with the advisory fee you pay LongView, when determining your total cost of investing. There is no assurance that the level of experience and service each individual IAR provides is uniform. LongView clients can pay more or less for the same service due to the experience, amount LongView Wealth Management of work done and sophistication of its Financial Planner. IRA Rollover Considerations As part of our consulting and advisory services, we may provide you recommendations and advice concerning your employer retirement plan or other qualified retirement account. Our recommendations may include you consider withdrawing the assets from your employer's retirement plan or other qualified retirement account and roll the assets over to an individual retirement account ("IRA"). Further, we offer our management services be applied to those funds and securities rolled into an IRA or other account for which we will receive compensation. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset based fee as described above under Item 5 of our ADV 2A . This practice presents a conflict of interest because persons providing investment advice on our behalf have an incentive to recommend a rollover to you for the purpose of generating fee based compensation rather than solely based on your needs. You are under no obligation, contractually or otherwise, to complete the rollover. Furthermore, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by us. It is important for you to understand many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of each. Leave the funds in your employer's (former employer's) plan. An employee will typically have four options: 1. 2. Move the funds to a new employer's retirement plan. 3. 4. Cash out and taking a taxable distribution from the plan. Roll the funds into an IRA rollover account. Each of these options has advantages and disadvantages and before making a change we encourage you to speak with your CPA and/or tax attorney. Determine whether the investment options in your employer's retirement plan address your Employer retirement plans generally have a more limited investment menu than IRAs. Employer retirement plans may have unique investment options not available to the public You should understand the various products and services you might take advantage of at an If you are considering rolling over your retirement funds to an IRA for us to manage it is important you understand the following: 1. needs or whether you might want to consider other types of investments. a. b. such as employer securities, or previously closed funds. 2. Your current plan may have lower fees than our fees. If you are interested in investing only in mutual funds, you should understand the cost structure a. of the share classes available in your employer's retirement plan and how the costs of those share classes compare with those available in an IRA. b. IRA provider and the potential costs of those products and services. c. It is likely you will not be charged a management fee and will not receive ongoing asset management services unless you elect to have such services. In the event your plan offers asset management or model management, there may be a fee associated with the services that is more or less than our asset management fee. 3. Our strategy may have higher risk than the option(s) provided to you in your plan. LongView Wealth Management Your current plan may offer financial advice, guidance, and/or model management or portfolio If you keep your assets titled in a 401k or retirement account, you could potentially delay your If you own company stock in your plan, you may be able to liquidate those shares at a lower 4. options at no additional cost. 5. required minimum distribution beyond age 70.5 (70 ½). Your 401k may offer more liability protection than a rollover IRA; each state may vary. 6. a. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally protected from creditors in bankruptcies. However, there can be some exceptions to the general rules so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. You may be able to take out a loan on your 401k, but not from an IRA. 7. 8. IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability, higher education expenses or the purchase of a home. 9. capital gains tax rate. 10. Your plan may allow you to hire us as the manager and keep the assets titled in the plan name. It is important that you understand the differences between these types of accounts and to decide whether a rollover is best for you. Prior to proceeding, if you have questions contact your investment adviser representative, or call our main number as listed on the cover page of this Appendix 1. Item 5 – ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS LongView generally requires a minimum amount of assets be deposited to an account for the purpose of obtaining asset management services through LongView. LongView may waive the minimum account size requirement and accept accounts less than the stated minimums. Such circumstances include but not be limited to additional assets will soon be deposited or you have other accounts under management with LongView. You are advised performance can suffer due to difficulties with diversifying smaller accounts and due to risk controls potentially being compromised. Performance of smaller accounts may vary from the performance of accounts with more dollars invested due to fluctuations in the market may affect smaller accounts more and the effects of compounding may be greater in larger accounts. LongView’s services are geared toward individuals both high net worth (i.e. clients with a net worth of $2,000,000) and other than high net worth, pension and profit-sharing plans, and corporations or other businesses. There is no minimum requirement for clients. Item 6 – PORTFOLIO MANAGER SELECTION AND EVALUATION LongView requires education and experience in investments, insurance, taxation, or other related fields as the minimum standard for their Advisory Representatives. LongView requires that all staff obtain appropriate licenses, including securities licenses to buy and sell securities and insurance products. In addition, LongView encourages professional staff to participate in industry education programs and in courses of study for Certified Financial Planner or Chartered Financial Consultant professional designations Your Advisory Representative is the sole manager on your account. Accounts are not assigned by LongView to any Advisory Representative. You retain the authority to select who you want to manage LongView Wealth Management your account. LongView’s Advisory Representatives have different education and experience levels and have different management styles and philosophies. Neither LongView nor a third-party reviews Advisory Representatives’ performance. LongView offers the following advisory services. Each of the services is more fully described in LongView’s Disclosure Appendix 1. • Asset Management • Financial Planning • Analysis, Recommendation and Monitoring of Third Party Managed Programs LongView tailors the advisory services it offers to your individual needs. You may impose restrictions and/or limitations on investing in certain securities or types of securities. LongView will ask you to complete a fact finder or data gathering questionnaire to assist LongView with obtaining information about your financial situation and history. Additionally, LongView will meet with you and conduct an interview and data gathering session to continue the due diligence process. The information gathered by LongView will assist LongView to provide you with the requested services and customize the services to your financial situation. Depending on the services you have requested, LongView will gather various financial information and history from you including, but not limited to: Investment objectives Investment horizon • Retirement and financial goals • • • Financial needs • Cash flow analysis • Cost of living needs • Education needs • Savings tendencies • Other applicable financial information required by LongView in order to provide the investment advisory services requested. As stated above, LongView offers the LongView Wealth Management Wrap Program. The program is offered as a wrap fee program and LongView’s Advisory Representatives are the portfolio managers. The wrap fee will be allocated to LongView and deducted from your Advisory Representative’s fee. LongView does not charge performance-based fees. LongView conducts economic analysis and attempts to analyze and determine the trends. Additionally, LongView conducts fundamental analysis. Fundamental analysis generally involves assessing a company’s or security’s value based on factors such as sales, assets, markets, management, products and services, earnings, and financial structure. LongView will conduct technical market analysis and technical trend following. Technical analysis generally involves studying trends and movements in a security’s price, trading volume, and other market-related factors in an attempt to discern patterns. LongView does not vote your securities. Unless you suppress proxies, securities proxies will be sent directly to you by the account custodian or transfer agent. You may contact LongView about questions LongView Wealth Management you may have an opinion on how to vote the proxies. However, the voting and how you vote the proxies is solely your decision. As of December 31, 2025, we managed approximately $1,153,392350 of client assets under management on a discretionary basis and $188,490 on a non-discretionary basis. Item 7 – CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS Your Advisory Representative will gather various information about you including, but not limited to, investment objectives and goals, personal information such as social security number, address, birth date and other information to verify your identity, financial information such as net worth, income, liquid net worth, prior investment experience, employer information, etc. During annual reviews your Advisory Representative will ask questions and may request you to complete updated account documents or verify the information you have provided remains current. Item 8 – CLIENT CONTACT WITH PORTFOLIO MANAGERS You may contact your Advisory Representative or any Advisory Representative of LongView at any time. Item 9 – ADDITIONAL INFORMATION Some of the Advisor’s investment advisor representatives are registered representatives of M.S. Howells & Co., a registered broker/dealer, member FINRA and SIPC. Clients are not obligated to purchase or sell securities through the investment advisor representatives in these separate capacities. However, if clients choose to implement the advice provided by Advisor through its investment advisor representatives in their separate capacities as registered representatives, M.S. Howells & Co. will be used, and commissions will be earned in addition to any fees paid for advisory services. LongView is not and does not have a related person who is a: futures commission merchant, commodity pool operator, commodity trading advisor, or an associated person of the foregoing entities. Further, LongView is not and does not have a related person who is: broker/dealer or other similar type of broker or dealer; investment company or other pooled investment vehicle, futures commission merchant or commodity pool operator; banking or thrift institution; accountant or accounting firm; lawyer or law firm; insurance company or agency; pension consultant; real estate broker or dealer; or sponsor or syndicator of a limited partnership. LongView attempts to mitigate conflicts of interest with the receipt of commissions if recommendations are implemented by providing you with these disclosures. Further, you are encouraged to consult other professionals and may implement recommendations through other financial professionals. Furthermore, as a registered representative with M.S. Howells & Co., Advisory Representatives are subject to a supervisory structure at M.S. Howells & Co. for their securities business. LongView and its management persons are not actively engaged in any other business. Further, LongView does not have a related person who is a: broker/dealer or other similar type of broker or dealer; investment company or other pooled investment vehicle; futures commission merchant or commodity pool operator; banking or thrift institution; accountant or accounting firm; lawyer or law firm; insurance company or agency; pension consultant; real estate broker or dealer; or sponsor or syndicator of a limited partnership. LongView Wealth Management LongView recommends other investment advisers (i.e. third-party managers) and will receive a portion of the fee charged to you by the investment adviser or will charge a fee in addition to the third- party managers. Since LongView has an interest in the compensation this is considered a material conflict of interest. LongView selects third party managers based on several criteria including cost, type of management, past history, ability to meet a need and provide a unique service. Since the fee charged to you is based on the value of your portfolio, all parties have an incentive to work toward performance goals and objectives. Consequently, if the third-party manager does not adequately manage your account and the value of your portfolio goes down, so does the third-party manager’s and LongView’s compensation. Code of Ethics B. LongView has a fiduciary duty to you to act in your best interest and always place your interests first and foremost. LongView takes seriously its compliance and regulatory obligations and requires all staff to comply with such rules and regulations as well as LongView’s policies and procedures. Further, LongView strives to handle your non-public information in such a way to protect information from falling into hands that have no business reason to know such information and provides you with LongView’s Privacy Policy. As such, LongView maintains a code of ethics for its Advisory Representatives, supervised persons and staff. The Code of Ethics contains provisions for standards of business conduct in order to comply with federal securities laws, personal securities reporting requirements, pre-approval procedures for certain transactions, code violations reporting requirements, and safeguarding of material non-public information about your transactions. Further, LongView’s Code of Ethics establishes LongView’s expectation for business conduct. A copy of our Code of Ethics will be provided to you upon request. Neither LongView nor its associated persons recommends to clients or buys or sells for client accounts any securities in which we have a material financial interest. LongView and its associated persons buy or sell securities identical to those securities recommended to you. Therefore, LongView and/or its associated persons have an interest or position in certain securities that are also recommended and bought or sold to you. LongView and its associated persons will not put their interests before your interest. LongView and its associated persons may not trade ahead of you or trade in such a way to obtain a better price for themselves than for you or other clients. LongView is required to maintain a list of all securities holdings for its associated persons and develop procedures to supervise the trading activities of associated persons who have knowledge of your transactions and their related family accounts at least quarterly. Further, associated persons are prohibited from trading on non-public information or sharing such information. You have the right to decline any investment recommendation. LongView and its associated persons are required to conduct their securities and investment advisory business in accordance with all applicable Federal and State securities regulations. Prohibition on Use of Insider Information LongView has adopted policies and procedures to prevent the misuse of “insider” information (i.e. material n, non-public information). A copy of such policies and procedures is available to any person upon request. LongView Wealth Management Review of Accounts C. You will be invited to participate in a review not less than at least annually or as agreed by you and your Advisory Representative. You may request more frequent reviews and may set thresholds for triggering events that would cause a review to take place. Your Advisory Representative will monitor for changes or shifts in the economy, changes to the management and structure of a mutual fund or company in which your assets are invested, and market shifts and corrections. You are advised that you must notify your Advisory Representative promptly of any changes to your financial goals, objectives or financial situation as such changes may require him review the potfolio allocation and make recommendations for changes. Clients participating in managed account programs will be provided statements at least quarterly direct from the account custodian. Additionally, you will receive confirmations of all transactions occuring direct from the account custodian. You may request additional account summary reports from LongView at any time. You should compare any report produced by LongView with statements received direct from the account custodian. Should there be any discrepancy the account custodian’s report will prevail. Client Referrals and Other Compensation D. Investment product vendors recommended by LongView can provide monetary and non-monetary assistance with client events, provide educational tools and resources. LongView does not select products as a result of any monetary or non-monetary assistance. LongView’s due diligence of a product does not take into consideration any assistance it may receive. However, the receipt of any form of compensation, either directly or indirectly, is considered a conflict of interest. We also receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab. In addition, Schwab has also agreed to pay for certain products and services for which we would otherwise have to pay once the value of our clients’ assets in accounts at Schwab reaches a certain size. You do not pay more for assets maintained at Schwab as a result of these arrangements. However, we benefit from the arrangement because the cost of these services would otherwise be borne directly by us. You should consider these conflicts of interest when selecting a custodian. The products and services provided by Schwab, how they benefit us, and the related conflicts of interest are described above. LongView mitigates this conflict of interest by supervising the activities of the Advisory Representatives, reviewing the investment recommendations provided to the clients, implementing policies and procedures, including the Code of Ethics. We also encourage you to discuss any recommendations provided by your Advisory Representative with another financial professional if you have any concerns about the appropriateness of the recommendation based on your financial situation. Our firm may engage in promoter arrangements for client referrals. These individual promoters offer our services to the public. The Firm pays a referral fee to the promoter based on a portion of the management fees charged by the Firm and memorialized in a written agreement (“Promoter Agreement”). In all cases, the Firm will comply with the cash solicitation rules established by the SEC, state regulators and the client disclosure requirements. If a referred prospective client enters into an investment advisory agreement with the Firm, a referral fee is paid to the referring party. The referral LongView Wealth Management relationship will not result in clients being charged any fees over and above the normal advisory fees charged for the advisory services provided. The Firm will pay the promoter their share of the total fee. The Promoter Agreement requires that the promoter be appropriately registered under federal and state securities laws where applicable. Clients receive all related agreements and disclosures prior to or at the time of entering into an Investment Advisory Agreement with the Firm. CUSTODY E. All client accounts are held at qualified custodians. LongView does not take physical custody of your funds or securities. LongView may be deemed to have constructive custody if a client has a standing letter of authorization (SLOA) to transfer funds or securities to a third party and LongView has the ability to direct transfers, change the amount, and/or the timing of the transfer. Under the applicable regulations, we are deemed to have custody of your assets if, for example, you authorize us to instruct your account custodian to deduct our advisory fees directly from your account or if you grant us authority to move your money to another person’s account. Your custodian maintains physical custody of your assets. You will receive account statements directly from your account custodian at least quarterly. They will be sent to the email or postal mailing address you provided. You should carefully review those statements promptly when you receive them. 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 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. Item 10 - REQUIREMENTS FOR STATE REGISTERED ADVISERS This section is not applicable to LongView. LongView is not state registered. LongView is registered with the Securities and Exchange Commission.