Lynch Investment Planning, LLC

Item 1: Cover Page Lynch Investment Planning, LLC Form ADV Part 2A Brochure Address: 2 Campus Boulevard Suite 106 Newtown Square, PA 19073 Phone: (484) 472-8956 Email: info@lynchip.com Website: https://www.lynchip.com/ This brochure provides information about the qualifications and business practices of Lynch Investment Planning, LLC (the “Adviser,” “we,” “us,” or “our”). If you have any questions about the contents of this brochure, please contact us at the telephone number or email address listed above. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Lynch Investment Planning, LLC is a registered investment adviser, but registration does not imply a certain level of skill or training. Additional information about Lynch Investment Planning, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov and by searching for CRD# 115956. Page 1 of 22 Date of Brochure: May 19, 2026  Item 2: Material Changes In this Item, we are only required to identify and discuss material changes since filing our last annual amendment. Since filing our last annual updating amendment on January 16, 2025, we have the following material changes to report: Brochure Item(s) Description Cover Page Items 4 & 5 The firm has updated its principal place of business The Firm has added Retirement Plan Consulting services Page 2 of 22 Date of Brochure: May 19, 2026  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes Item 3: Table of Contents Item 4: Advisory Business Item 5: Fees and Compensation Item 6: Performance-Based Fees & Side-By-Side Management Item 7: Types of Clients Item 8: Methods of Analysis, Investment Strategies & Risk of Loss Item 9: Disciplinary Information Item 10: Other Financial Industry Activities & Affiliations Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading Item 12: Brokerage Practices Item 13: Review of Accounts Item 14: Client Referrals and Other Compensation Item 15: Custody Item 16: Investment Discretion Item 17: Voting Client Securities Item 18: Financial Information 1 2 3 4 6 9 10 11 13 14 15 16 17 18 19 20 21 22 Page 3 of 22 Date of Brochure: May 19, 2026  Item 4: Advisory Business A. Lynch Investment Planning, LLC is an investment adviser founded in 2021, registered with the U.S. Securities and Exchange Commission (“SEC”), and principally owned by David Lynch and Michael Lynch. B. We offer the following types of advisory services: i. Investment Management. We provide ongoing discretionary and non-discretionary investment management services to our clients based upon each client’s current financial condition, goals, risk tolerance, income, liquidity requirements, investment time horizon, and other information that is relevant to the management of the client’s accounts. This information will then be used to make investment decisions and recommendations that reflect the client’s individual needs and objectives on an initial and ongoing basis. Our investment decisions and recommendations will allocate portions of the client’s accounts to various asset classes classified according to historical and projected risks and rates of return. For accounts in which we have been granted discretionary authority, we will retain the discretion to buy, sell, or otherwise transact in securities and other investments in the client’s accounts without first receiving the client’s specific approval for each transaction. Such discretionary authority is granted by the client in our services agreement. For non-discretionary accounts, we may only buy, sell, or otherwise transact in securities and other investments in the client’s accounts upon receiving the client’s specific approval for each transaction. The client may impose restrictions on investing in certain securities or types of securities so long as we can reasonably implement such restrictions. We typically implement our investment strategy by allocating clients’ investable assets across a diversified risk-based portfolio of exchange traded funds (“ETFs”), mutual funds, stocks, bonds, and cash equivalents. ii. Financial Planning. When rendering financial planning services (which may be provided in conjunction with our investment management services or as a standalone service), we will evaluate and make recommendations with respect to various financial planning topics that are relevant to the particular client. Such topics can include, for example, retirement planning, education savings, cash flow management, debt reduction, estate planning, insurance needs, risk mitigation, tax planning, charitable giving strategies, and/or financial goal tracking. Implementation of our recommendations will be at the discretion of the client. When rendering financial planning services, a conflict exists between our interests and the interests of our clients. The client is under no obligation to act upon our financial planning recommendations. If the client elects to act on any of the recommendations we make, the client is under no obligation to effect the transaction through us or any of our personnel. iii. Pension Consulting Services. To the extent we are retained by a defined contribution plan, defined benefit plan, or other employee benefit plan (a “Plan”), we shall review the Plan’s investment objectives, risk tolerance, and goals, and shall work in partnership with applicable third-parties (such as the Plan’s recordkeeper, third-party administrator, and/or discretionary investment manager) to establish an appropriate investment policy statement and deploy applicable investment options into the Plan’s account. We shall periodically review the investment options available to the Plan and, if applicable, will make recommendations to assist the Plan with respect to the selection of the Plan’s qualified default investment alternative (“QDIA”). We will provide reports, information and recommendations, on a reasonably requested basis, to assist the Plan in monitoring the selected investments. If elected by the Plan, we may also provide various services Page 4 of 22 Date of Brochure: May 19, 2026  related to the Plan’s governance, the education of Plan participants, and the review of other service providers to the Plan. In connection with Plans subject to the Employee Retirement Income Security Act of 1974 (“ERISA”) and applicable provisions of the Internal Revenue Code of 1986, as amended (the “Code”) we acknowledge that we are a fiduciary under ERISA and the Code, shall render prudent investment advice that is in the Plan’s best interest, shall avoid making misleading statements, and shall receive no more than reasonable compensation. iv. Tax Preparation and Filing. Our founder, James Lynch, provides state and federal income tax preparation and filing services for certain clients in the weeks leading up to the April 15th annual tax filing deadline. C. We do not sponsor or participate in any wrap fee programs. D. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (the “Code”), as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: i. Meet a professional standard of care when making investment recommendations (give ii. iii. iv. prudent advice); Never put our financial interests ahead of yours when making recommendations (give loyal advice); Avoid misleading statements about conflicts of interest, fees, and investments; Follow policies and procedures designed to ensure that we give advice that is in your best interest; Charge no more than is reasonable for our services; and v. vi. Give you basic information about conflicts of interest. E. We manage the following amount of discretionary and non-discretionary client assets calculated as of December 31, 2025: Discretionary: Non-Discretionary: Total: $133,516,745 $9,734,099 $143,250,844 Page 5 of 22 Date of Brochure: May 19, 2026  Item 5: Fees and Compensation A. We charge asset-based and/or flat fees for our services, depending on the specific services for which you engage us. Our fees and fee ranges as set forth herein reflect the typical fees we charge to clients; however, the specific fees charged to a particular client will vary from client to client. Each client should review the services agreement signed with us for the fees that will be charged and how fees will be payable. Our fees may vary from client to client due to historical or ‘grandfathered’ fee schedules that are no longer offered, the nature and scope of the services to be provided to the client, personal or familial relationships with the client, and other factors that we deem relevant. Fees are negotiable, but we reserve the right to accept or reject different fees proposed by the client. B. Investment Management. We are compensated for our investment management services by fees charged based on the client’s assets designated to be under our management, advisement, and/or supervision. Our typical asset-based fee schedule is set forth in the table below, subject to a minimum annual fee of $2,500 per year (applied in monthly increments): Annual Fee Percentage Client Assets Under Management, Advisement, and/or Supervision On the first $100,000.00 On the next $250,000.00 On the next $500,000.00 On the next $1,000,000.00 On the remaining amount 1.25% 1.00% 0.85% 0.75% 0.50% The asset-based fees set forth above reflect a “tiered” or “blended” fee schedule, which means that different annual fee percentages will apply to different ranges of client assets under Adviser’s management. Fees are charged monthly in arrears and based upon the gross market value of the client’s assets designated to be under our management, advisement, and/or supervision as of the last business day of the calendar month, multiplied by one-twelfth (1/12) of the annual fee percentage. Asset-based fees are prorated from the date that the client’s assets are first designated to be under our management, advisement, and/or supervision through the effective date of termination of our engagement. Accounts that are opened or closed during the month shall be charged a pro rata fee in consideration of the period of time for which the account is designated to be under our management, advisement, and/or supervision. Asset-based fees are generally deducted from one or more of the client’s accounts under our management, advisement, and/or supervision, but we may also agree to accept payment via third-party payment processor or check. If a client service agreement is terminated during the month, the pro rata fees earned through the effective date of the termination will be billed to the client. C. Standalone Financial Planning. In consideration of our standalone financial planning services (that are not provided in conjunction with investment management services), we charge a minimum one-time flat fee of $2,500 per engagement. Twenty-five percent (25%) of the flat fee is generally due upon initial engagement, with the balance due upon satisfactory completion of the standalone financial planning services to be rendered. The flat fee is based on the nature, complexity, and scope of the financial planning services to be rendered. Page 6 of 22 Date of Brochure: May 19, 2026  In the event of early termination before the completion of our standalone financial planning engagement, any prepaid but unearned fees will be refunded to the client based on the percentage of services completed up to the effective date of termination; conversely, any earned but unpaid fees will be due and payable by the client based on the percentage of services completed up to the effective date of termination. Upon termination of our engagement, any completed deliverables will be provided to the client. D. Pension Consulting Services. We are compensated for our pension consulting services by fees charged based on the gross market value of a Plan’s assets designated to be under our management, advisement, and or supervision as of the last business day of the calendar month, multiplied by one-twelfth (1/12) of the annual fee percentage. Our typical asset-based fee schedule ranges from 0.25% to 1.00% per year, subject to a minimum annual fee of $2,500 per year (applied in monthly increments). Our asset-based pension consulting fee is typically a flat percentage amount applied to all assets in the Plan, deducted pro rata across all participant accounts (though we may alternatively agree to accept payment from the Plan sponsor via third-party payment processor or check. Asset-based fees are prorated from the date that the Plan’s assets are first designated to be under our management, advisement, and/or supervision through the effective date of termination of our engagement. Accounts that are opened or closed during the month shall be charged a pro rata fee in consideration of the period of time for which the account is designated to be under our management, advisement, and/or supervision. If a client service agreement is terminated during the month, the pro rata fees earned through the effective date of the termination will be billed to the client. E. Tax Preparation and Filing. In consideration of our state and federal income tax return preparation and filing services, we generally charge a flat fee that ranges from $200 to $1,000 per engagement, charged in arrears upon filing of the applicable income tax return(s). The flat fee will vary based on the nature and complexity of the client’s tax situation and the corresponding income tax returns to be prepared and filed. Tax preparation and filing fees are payable via third-party payment processor or check. F. General Fee Disclosures. Neither we nor any of our supervised persons accept compensation for the sale of securities or other investment products. However, David Lynch is a licensed insurance agent and from time to time will earn a commission from the sale of an insurance product. This creates a conflict of interest, because David Lynch has the potential to earn both an insurance commission and advisory fee revenue from a client. David Lynch addresses this conflict of interest by fully disclosing his relationship with the applicable insurance provider, and informing clients that they are under no obligation to purchase an insurance product through him. In addition to the fees charged by Adviser, clients will incur brokerage and other transaction costs. Please refer to Item 12: Brokerage Practices, for further information on such brokerage and other transaction-related practices. Depending on the specific investment products held in a client’s account and the services provided, a client may also incur additional fees and costs charged by other independent and unaffiliated third-parties. Such additional fees and costs may include, but are not necessarily limited to, the internal fees and costs of an investment product (like a mutual fund or exchange traded fund), margin interest, account or asset transfer fees, subadvisory or third-party investment manager fees, account type fees, early redemption charges, market-maker or bid-ask spreads, retirement plan fees, trade-away or prime brokerage fees, fees for receiving paper copies of documents in lieu of electronically-delivered documents, and other fees and taxes on brokerage accounts and securities transactions. These additional charges are separate and Page 7 of 22 Date of Brochure: May 19, 2026  apart from the fees charged by Adviser. Lower fees for comparable services may be available from other sources. Page 8 of 22 Date of Brochure: May 19, 2026  Item 6: Performance-Based Fees & Side-By-Side Management Neither we nor any of our supervised persons accept performance-based fees (fees based on a share of capital gains or capital appreciation of the assets of a client). Neither we nor any of our supervised persons engage in side-by-side management. Page 9 of 22 Date of Brochure: May 19, 2026  Item 7: Types of Clients We generally provide our services to individuals, high-net-worth individuals, charitable organizations, foundations, endowments, and defined contribution plans, defined benefit plans, or other employee benefit plans. There is no minimum account size, but there is a minimum fee of $2,500 per year for our services. Page 10 of 22 Date of Brochure: May 19, 2026  Item 8: Methods of Analysis, Investment Strategies & Risk of Loss A. Our methods of analysis and investment strategies include asset-allocation based on the specific financial situation and investment objectives of the client. Our asset-allocation strategies are typically implemented using mutual funds and ETFs, but we also incorporate stocks, bonds, and other equity and fixed income securities as appropriate for a particular client’s needs. Investing in securities involves risk of loss that clients should be prepared to bear. Past performance does not guarantee future returns. B. Like any investment strategy, ours involves material risks. Such material risks are described in further detail below: i. Investing for the long term means that a client’s account will be exposed to short-term fluctuations in the market and the behavioral impulse to make trading decisions based on such short-term market fluctuations. We do not condone short-term trading in an attempt to “time” the market, and instead coach clients to remain committed to their financial goals. However, investing for the long term can expose clients to risks borne out of changes to interest rates, inflation, general economic conditions, market cycles, geopolitical shifts, and regulatory changes. ii. Inflation risk is the risk that the value of a client’s portfolio will not appreciate at least in an amount equal to inflation over time. General micro- and macro-economic conditions may also affect the value of the securities held in a client’s portfolio, and general economic downturns can trigger corresponding losses across various asset classes and security types. Market cycles may cause overall volatility and fluctuations in a portfolio’s value, and may increase the likelihood that securities are purchased when values are comparatively high and/or that securities are sold when values are comparatively low. Geopolitical shifts may result in market uncertainty, lowered expected returns, and general volatility in both domestic and international securities. Regulatory changes may have a negative impact on capital formation and increase the costs of doing business, and therefore result in decreased corporate profits and corresponding market values of securities. iii. Investing in mutual funds does not guarantee a return on investment, and shareholders of a mutual fund may lose the principal that they’ve invested into a particular mutual fund. Mutual funds invest into underlying securities that comprise the mutual fund, and as such clients are exposed to the risks arising from such underlying securities. Mutual funds charge internal expenses to their shareholders (which can include management fees, administration fees, shareholder servicing fees, sales loads, redemption fees, and other fund fees and expenses, e.g.), and such internal expenses subtract from its potential for market appreciation. Shares of mutual funds may only be traded at their stated net asset value (“NAV”), calculated at the end of each day upon the market’s close. Investing in ETFs bears similar risks and incurs similar costs to investing in mutual funds as described above. However, shares of an ETF may be traded like stocks on the open market and are not redeemable at an NAV. As such, the value of an ETF may fluctuate throughout the day and investors will be subject to the cost associated with the bid-ask spread (the difference between the price a buyer is willing to pay (bid) for an ETF and the seller's offering (asking) price). Clients are encouraged to carefully read the prospectus of any mutual fund or ETF to be Page 11 of 22 Date of Brochure: May 19, 2026  purchased for investment to obtain a full understanding of its respective risks and costs. iv. Investing in common stocks means that a client will be subject to the risks of the overall market as well as risks associated with the particular company or companies whose stock is owned. These risks can include, for example, changes in economic conditions, growth rates, profits, interest rates and the market’s perception of these securities. Common stocks tend to be more volatile and more risky than certain other forms of investments, especially as compared to fixed income products like bonds. v. Investing in fixed income securities issued by the U.S. Government, including Treasury Bills, Treasury Notes, Treasury Bonds, Treasury Inflation-Protected Securities (“TIPS”), and Floating Rate Notes means that a client will be subject to the market prices of such debt securities, which typically fluctuate depending on interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and rise when interest rates fall. The longer the time to a security’s maturity, the greater its interest rate risk. Fixed income securities issued by the U.S. Government are also subject to inflation risk, reinvestment risk, redemption risk, and valuation risk. vi. Investing in municipal securities carries unique risks, depending on the type of bond offered. General obligation bonds are issued by governmental entities and are not backed by revenues from a specific project or source. In some instances, municipalities may not have taxing authority to repay bondholders. Revenue bonds are backed by revenues from a specific project or source and can vary greatly in terms of credit risk. Some revenue bonds are “non-course” bonds, meaning that should the revenue stream dry up or the conduit borrower fails to pay, the bondholder will not have a claim to the underlying revenue or against the conduit borrower. Page 12 of 22 Date of Brochure: May 19, 2026  Item 9: Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of our advisory business or the integrity of our management. Page 13 of 22 Date of Brochure: May 19, 2026  Item 10: Other Financial Industry Activities & Affiliations A. Neither we nor any of our management persons are registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. B. Neither we nor any of our management persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. C. Neither we nor any of our management persons have any relationship or arrangement with any related person below: i. ii. iii. iv. v. vi. vii. viii. ix. x. broker-dealer, municipal securities dealer, or government securities dealer or broker investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or “hedge fund,” and offshore fund) other investment adviser or financial planner futures commission merchant, commodity pool operator, or commodity trading advisor banking or thrift institution accountant or accounting firm lawyer or law firm pension consultant real estate broker or dealer sponsor or syndicator of limited partnerships D. David Lynch is a licensed insurance agent and from time to time will earn an ordinary and customary commission from the sale of an insurance product in such capacity. This creates a conflict of interest, because David Lynch has the potential to earn both an insurance commission and advisory fee revenue from a client. David Lynch addresses this conflict of interest by fully disclosing his relationship with the applicable insurance provider, and informing clients that they are under no obligation to purchase an insurance product through him. E. We incorporate mutual funds and ETFs sponsored and managed by Dimensional Fund Advisors LP (“Dimensional”) in accounts we manage for clients, and we use John Hancock Retirement Plan Services, LLC and John Hancock Trust Company LLC (collectively “John Hancock”) in conjunction with our pension consulting services. We do not receive any compensation directly from Dimensional or John Hancock, but both offer services that are intended to directly benefit us, clients, or both. More specifically, Dimensional and John Hancock offer an online portal through which we can access research reports, white papers, and other educational materials. The availability of these materials from Dimensional and John Hancock creates a conflict of interest to the extent we may be motivated to use Dimensional mutual funds or ETFs as opposed to an alternative mutual fund or ETF provider, and to the extent we may be motivated to use John Hancock in conjunction with our pension consulting services, respectively. We address this conflict of interest by performing appropriate due diligence on Dimensional and John Hancock to confirm their respective services are in the best interests of clients, periodically evaluating alternatives, and evaluating their merit without consideration of the benefits we receive. Page 14 of 22 Date of Brochure: May 19, 2026  Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading A. We have adopted a code of ethics that will be provided to any client or prospective client upon request. Our code of ethics describes the standards of business conduct that we require of our supervised persons, which is reflective of our fiduciary obligations to act in the best interests of clients. The code of ethics also includes sections related to compliance with securities laws, reporting of personal securities transactions and holdings, reporting of violations of the code of ethics to our Chief Compliance Officer, pre-approval of certain investments by access persons, and the distribution of the code of ethics and any amendments to all supervised persons followed by a written acknowledgement of their receipt. B. Neither we nor any of our related persons recommends to clients, or buys or sells for client accounts, securities in which we or any of our related persons has a material financial interest. C. From time to time, we or our related persons will invest in the same securities (or related securities such as warrants, options or futures) that we or a related person recommend to clients. This has the potential to create a conflict of interest because it affords us or our related persons the opportunity to profit from the investment recommendations made to clients. Our policies and procedures and code of ethics address this conflict of interest by prohibiting such trading by us or our related persons if it would be to the detriment of any client and by monitoring for compliance through the reporting and review of personal securities transactions. In all instances, we will act in the best interests of our clients. D. From time to time, we or our related persons will buy or sell securities for client accounts at or about the same time that we or a related person buys or sells the same securities for our own (or the related person’s own) account. This has the potential to create a conflict of interest because it affords us or our related persons the opportunity to trade either before or after the trade is made in client accounts, and profit as a result. Our policies and procedures and code of ethics address this conflict of interest by prohibiting such trading by us or its related persons if it would be to the detriment of any client and by monitoring for compliance through the reporting and review of personal securities transactions. In all instances, we will act in the best interests of our clients. Page 15 of 22 Date of Brochure: May 19, 2026  Item 12: Brokerage Practices A. We consider several factors when recommending a custodial broker-dealer for client transactions and determining the reasonableness of such custodial broker-dealer’s compensation. Such factors include the custodial broker-dealer’s industry reputation and financial stability, service quality and responsiveness, execution price, speed and accuracy, reporting abilities, and general expertise. Assessing these factors as a whole allows us to fulfill our duty to seek best execution for client securities transactions. However, we do not guarantee that the custodial broker-dealer recommended for client transactions will necessarily provide the best possible price, as price is not the sole factor considered when seeking best execution. After considering the factors above, we recommend Charles Schwab & Co., Inc. ("Schwab") as the custodial broker-dealer for client accounts. i. We do not receive research and other soft dollar benefits in connection with client securities transactions, which are known as “soft dollar benefits”. However, the custodial broker-dealer we recommend does provide certain products and services that are intended to directly benefit us, clients, or both. Such products and services include (a) an online platform through which we can monitor and review client accounts, (b) access to proprietary technology that allows for order entry, (c) duplicate statements for client accounts and confirmations for client transactions, (d) invitations to the custodial broker-dealer’s educational conferences, (e) practice management consulting, (f) occasional business meals and entertainment, and (g) occasional business meals and entertainment. The receipt of these products and services creates a conflict of interest to the extent it causes us to recommend Schwab as opposed to a comparable custodial broker-dealer. We address this conflict of interest by fully disclosing it in this brochure, evaluating Schwab based on the value and quality of its services as realized by clients, and by periodically evaluating alternative custodial broker-dealers to recommend. ii. We do not consider, in selecting or recommending custodial broker-dealers, whether we or a related person receives client referrals from a custodial broker-dealer. iii. We do not routinely recommend, request, or require that a client direct us to execute transactions through a specified custodial broker-dealer other than Schwab. B. We retain the ability to aggregate the purchase and sale of securities for clients’ accounts with the goal of seeking more efficient execution and more consistent results across accounts. Aggregated trading instructions will not be placed if it would result in increased administrative and other costs, custodial burdens, or other disadvantages. If we aggregate client trades, such aggregation will be done so as not to disadvantage any client and to treat all clients as fairly and equally as possible. Directing the purchase and sale of securities for clients’ accounts on an individual basis, rather than in aggregate blocks, may result in increased client transaction costs. To the extent the securities purchased and sold by us are mutual funds (each of which generally price at the same respective net asset value at the end of each trading day), we believe that the potential for increased client transaction costs by not aggregating orders is substantially eliminated. Page 16 of 22 Date of Brochure: May 19, 2026  Item 13: Review of Accounts A. Our investment adviser representatives monitor client accounts on an ongoing basis, and typically review client accounts on at least an annual basis. Such reviews are designed to ensure that the client is still on track to achieve the client’s financial goals, and that the investments remain appropriate given the client’s risk tolerance, investment objectives, major life events, and other factors. Clients are encouraged to proactively reach out to us to discuss any changes to their personal or financial situation. B. Other factors that may trigger a review include, but are not limited to, material developments in market conditions, material geopolitical events, and changes to a client’s personal or financial situation (the birth of a child, preparing for a home purchase, plans to attend higher education, a job transition, impending retirement, death or disability among family members, etc.). C. The custodial broker-dealer will send account statements and reports directly to clients no less frequently than quarterly. Such statements and reports will be mailed to clients at their address of record or delivered electronically, depending on the client’s election. We or a third-party report provider may also agree to make certain reports available to clients to assist them in understanding their account positions and performance, as well as the progress toward achieving financial goals. Page 17 of 22 Date of Brochure: May 19, 2026  Item 14: Client Referrals and Other Compensation A. Only clients provide an economic benefit to us for providing investment advice or other advisory services to them, except as otherwise described in this brochure. However, as described above in Items 10 and 12, Dimensional, John Hancock, and Schwab offer certain products and services that are intended to directly benefit us, clients, or both. B. Neither we nor a related person directly or indirectly compensates a person who is not our supervised person for client referrals. Page 18 of 22 Date of Brochure: May 19, 2026  Item 15: Custody For clients that do not have their fees deducted directly from their accounts, we will not have any custody of client funds or securities. For clients that have their fees deducted directly from their accounts, we will generally be deemed to have custody over such clients’ funds pursuant to applicable custody rules and guidance thereto. At no time will we accept custody of client funds or securities in the capacity of a custodial broker-dealer or other qualified custodian, and at all times client accounts will be held by a third-party qualified custodian as described in Item 12, above. If a client receives account statements from both the custodial broker-dealer and us or a third-party report provider, such client is urged to compare such account statements and advise us of any discrepancies between them. Page 19 of 22 Date of Brochure: May 19, 2026  Item 16: Investment Discretion We accept discretionary trading authority to manage securities accounts on behalf of clients only pursuant to the mutual written agreement of us and the client through a power-of-attorney, which is typically contained in the advisory agreement signed by the client. This includes the authority to buy, sell, and otherwise transact in securities and other investment products in clients’ accounts without necessarily consulting with clients in advance. Clients may place reasonable limitations on this discretionary authority so long as it is contained in a written agreement and/or power-of-attorney. Page 20 of 22 Date of Brochure: May 19, 2026  Item 17: Voting Client Securities A. We do not have and will not accept authority to vote client securities. B. Clients will receive their proxies or other solicitations directly from their custodial broker-dealer or a transfer agent, as applicable, and should direct any inquiries regarding such proxies or other solicitations directly to the sender. Page 21 of 22 Date of Brochure: May 19, 2026  Item 18: Financial Information A. We do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. B. We have no financial condition that is reasonably likely to impair our ability to meet contractual commitments to clients. C. We have not been the subject of a bankruptcy petition at any time during the past ten years. Page 22 of 22 Date of Brochure: May 19, 2026