MASSO TORRENCE WEALTH MANAGEMENT INC.

Masso Torrence Wealth Management Inc. Form ADV Part 2A – Disclosure Brochure Effective: April 16, 2025 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Masso Torrence Wealth Management Inc. (“Masso Torrence” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at (856) 988-6664. Masso Torrence is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about Masso Torrence to assist you in determining whether to retain the Advisor. Additional information about Masso Torrence and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 311097. Masso Torrence Wealth Management Inc. 270 N Elmwood Road, Suite H-160, Marlton, NJ 08053 Phone: (856) 988-6664 | Fax: (856) 861-1885 https://www.massotorrence.com  Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of Masso Torrence. For convenience, the Advisor has combined these documents into a single disclosure document. Masso Torrence believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. Masso Torrence encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes Since the last filing on February 19, 2025, there were material changes made to this Disclosure Brochure. Item 10. Other Financial Industry Activities and Affiliations: Certain of our members are no longer Registered Representatives of a Purshe Kaplan Sterling Investments, Inc. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 311097. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (856) 988-6664. Masso Torrence Wealth Management Inc. 270 N Elmwood Road, Suite H-160, Marlton, NJ 08053 Phone: (856) 988-6664 | Fax: (856) 861-1885 https://www.massotorrence.com  Item 3 – Table of Contents Item 2 – Material Changes ................................................................................................................................................. 2 Item 3 – Table of Contents ................................................................................................................................................. 3 Contents Item 4 – Advisory Services ................................................................................................................................................ 4 A. Firm Information ......................................................................................................................................................................... 4 B. Advisory Services Offered .......................................................................................................................................................... 4 C. Client Account Management ....................................................................................................................................................... 6 D. Wrap Fee Programs ................................................................................................................................................................... 6 E. Assets Under Management ........................................................................................................................................................ 6 Item 5 – Fees and Compensation ....................................................................................................................................... 6 A. Fees for Advisory Services ......................................................................................................................................................... 6 B. Fee Billing ................................................................................................................................................................................... 7 C. Other Fees and Expenses .......................................................................................................................................................... 8 D. Advance Payment of Fees and Termination ............................................................................................................................... 8 E. Compensation for Sales of Securities ......................................................................................................................................... 9 Item 6 – Performance-Based Fees and Side-By-Side Management .............................................................................. 9 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ...................................................................... 9 A. Methods of Analysis ................................................................................................................................................................... 9 B. Risk of Loss .............................................................................................................................................................................. 10 Item 9 – Disciplinary Information .................................................................................................................................... 11 Item 10 – Other Financial Industry Activities and Affiliations ..................................................................................... 11 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .......................... 12 A. Code of Ethics .......................................................................................................................................................................... 12 B. Personal Trading with Material Interest ..................................................................................................................................... 12 C. Personal Trading in Same Securities as Clients ....................................................................................................................... 12 D. Personal Trading at Same Time as Client ................................................................................................................................ 12 Item 12 – Brokerage Practices ........................................................................................................................................ 12 A. Recommendation of Custodian[s] ............................................................................................................................................. 12 B. Aggregating and Allocating Trades ........................................................................................................................................... 13 Item 13 – Review of Accounts ......................................................................................................................................... 13 A. Frequency of Reviews .............................................................................................................................................................. 13 B. Causes for Reviews .................................................................................................................................................................. 13 C. Review Reports ........................................................................................................................................................................ 13 Item 14 – Client Referrals and Other Compensation .................................................................................................... 14 A. Compensation Received by Masso Torrence ........................................................................................................................... 14 B. Client Referrals from Solicitors ................................................................................................................................................. 14 Item 15 – Custody ............................................................................................................................................................. 14 Item 16 – Investment Discretion ..................................................................................................................................... 15 Item 17 – Voting Client Securities ................................................................................................................................... 15 Item 18 – Financial Information ....................................................................................................................................... 15 Privacy Policy ................................................................................................................................................................... 16 Our Commitment to You ............................................................................................................................................................... 16 Masso Torrence Wealth Management Inc. 270 N Elmwood Road, Suite H-160, Marlton, NJ 08053 Phone: (856) 988-6664 | Fax: (856) 861-1885 https://www.massotorrence.com  Item 4 – Advisory Services A. Firm Information Masso Torrence Wealth Management Inc. (“Masso Torrence” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor was organized as a Limited Liability Company (“LLC”) under the laws of the State of New Jersey in October 2007 and became a registered investment advisor in November 2020. Masso Torrence is owned by Christopher J. Masso (Managing Partner), John M. Torrence (Managing Partner and Chief Compliance Officer), and Nicholas P. Pantle (Managing Partner). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Masso Torrence. B. Advisory Services Offered Wealth Management Services Masso Torrence offers wealth management services which include investment management, financial planning and/or other advisory services to individuals, high net worth individuals, trusts, estates, retirement plans, and small businesses (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Masso Torrence's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Masso Torrence provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. Masso Torrence works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Masso Torrence will then construct an investment portfolio, consisting exchange-traded funds (“ETFs”), open-end mutual funds, individual stocks, individual bonds, and closed-end mutual funds. The Advisor may also utilize covered options, limited partnerships, and/or other types in investments, as appropriate, to meet the needs of the Client. The Advisor may retain certain types of investments based on a Client’s legacy investments based on portfolio fit and/or tax considerations. Masso Torrence’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Masso Torrence will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Masso Torrence evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Masso Torrence may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Masso Torrence may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Masso Torrence may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will Masso Torrence accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Masso Torrence Wealth Management Inc. 270 N Elmwood Road, Suite H-160, Marlton, NJ 08053 Phone: (856) 988-6664 | Fax: (856) 861-1885 https://www.massotorrence.com  Financial Planning Services Masso Torrence will typically provide a variety of financial planning and consulting services to Clients, either as a component of wealth management services or pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs, and/or other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Masso Torrence may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly. Retirement Plan Advisory Services Masso Torrence provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: Investment Policy Statement (“IPS”) Design and Monitoring Investment Oversight Services (ERISA 3(21)) • Vendor Analysis • Plan Participant Enrollment and Education Tracking • Plan Participant Advice • • • Performance Reporting • Ongoing Investment Recommendation and Assistance These services are provided by Masso Torrence serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Masso Torrence’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. Investment Consulting Services The Advisor offers investment consulting services to individuals and families, either as a component of investment management services or pursuant to a written investment consulting agreement. When offered as a separate engagement, this service is ideal for Clients seeking a smaller scope engagement and to utilize the expertise of the Advisor but without having an account managed by the Advisor. Services are offered in several areas of a Client’s financial situation, depending on their goals, objectives and financial situation. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Third-Party Money Management Services: The Advisor may recommend third-party money managers (“TPMMs”) to manage part or the client’s entire portfolio. TPMMs may be recommended when the TPMMs’ philosophy, investment strategy, and style meets the client's Masso Torrence Wealth Management Inc. 270 N Elmwood Road, Suite H-160, Marlton, NJ 08053 Phone: (856) 988-6664 | Fax: (856) 861-1885 https://www.massotorrence.com  financial situation, investment objectives, and risk tolerance. The asset management services provided by the TPMMs, the compensation to be paid, and other terms of the relationship between the client and the TPMMs will be described in the TPMMs’ disclosure documents and its managed account agreement. We will receive a portion of the investment advisory fee paid by the client to the TPMMs. C. Client Account Management Prior to engaging Masso Torrence to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: • Establishing an Investment Strategy – Masso Torrence, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. • Asset Allocation – Masso Torrence will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. • Portfolio Construction – Masso Torrence will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – Masso Torrence will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Masso Torrence does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Masso Torrence. E. Assets Under Management As of December 31, 2024, Masso Torrence manages $326,547,081 in Client assets on a discretionary basis only. Clients may request more current information at any time by contacting the Advisor. Masso Torrence provided advice and guidance on $103,440,946 on an assets under advisement basis. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one more written agreements with the Advisor. A. Fees for Advisory Services Wealth Management Services Wealth management fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the wealth management agreement. Wealth management fees are based on the market value of assets under management at the end of the prior calendar quarter. Wealth management fees range from 0.25% to 1.25% annually and are either a fixed annual rate or a tiered fee schedule. The wealth management fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. Certain Clients may be offered a fixed rate fee schedule. Clients with assets under management up to $500,000 are offered services at a fixed annual fee of $5,000 plus 0.30%. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by Masso Torrence will be independently valued by the Custodian. Masso Torrence will not have the authority or responsibility to value portfolio securities. Clients may make additions to and withdrawals from their account[s] at any time, subject to Masso Torrence’s right to terminate an account. Additions may be in cash or securities provided that Masso Torrence reserves the right to liquidate any transferred securities or decline to accept particular securities into a Client’s account[s]. Clients may withdraw account assets on notice to Masso Torrence, subject to the usual and customary securities settlement procedures. However, Masso Torrence designs its portfolios as long-term investments, and the withdrawal of assets may impair the achievement of a Client’s investment objectives. Masso Torrence may consult with its Clients about the options and ramifications of transferring securities. However, Clients are advised that when transferred securities are liquidated, they Masso Torrence Wealth Management Inc. 270 N Elmwood Road, Suite H-160, Marlton, NJ 08053 Phone: (856) 988-6664 | Fax: (856) 861-1885 https://www.massotorrence.com  may be subject to transaction fees, fees assessed at the mutual fund level (i.e. contingent deferred sales charge) and/or tax ramifications. The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. Financial Planning Services Masso Torrence typically offers financial planning services as part of an overall wealth management engagement. In certain instances, the Advisor may engage for these services separately. Fees are billed at an hourly rate of $350 per hour or a negotiated fixed engagement fee. Fees may be negotiable based on the nature and complexity of the services to be provided and the overall relationship with the Advisor. An estimate for total hours and/or total costs will be provided to the Client prior to engaging for these services. Investment Consulting Services Investment consulting fees are paid quarterly, at the end of each calendar quarter, pursuant to the terms of the investment consulting agreement. Investment consulting fees are determined at the outset of each engagement. The fee, depending on the scope of service and/or the Clients situation, may be a flat annual dollar amount agreed upon between the Advisor and Client, or may range from 0.10% to 0.90% annually, depending on the asset size under advisement. Investment consulting fees that are charged as a percentage of the advised assets per the investment consulting agreement are based on the market value of those assets at the end of each quarter. The investment consulting fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. Retirement Plan Advisory Services Fees for retirement plan advisory services are charged an annual asset-based fee ranging from 0.10% to 1.50%, depending on the scope, complexity and size of the Plan. Fees are billed pursuant to the terms of the retirement plan advisory agreement and may be deducted from Plan assets or paid by the Plan Sponsor. Fees may be in advance of or at the end of a calendar quarter or month. Retirement plan advisory fees are based on the market value of assets under management at the end of the prior calendar quarter fees may be negotiable depending on the size and complexity of the Plan. B. Fee Billing Wealth Management Services Wealth management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the beginning of the respective quarter. The amount due is calculated by applying the quarterly rate (the total number of days in the quarter divided by the number of days in the year then multiplied by the annual rate) to the total assets under management with Masso Torrence at the end of the prior quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. In addition, the Advisor will provide the Client a report itemizing the fee, including the calculation period covered by the fee, the account value and the methodology used to calculate the fee. Clients are urged to also review and compare the statement provided by the Advisor to the brokerage statement from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written authorization permitting advisory fees to be deducted by Masso Torrence to be paid directly from their account[s] held by the Custodian as part of the wealth management agreement and separate account forms provided by the Custodian. Financial Planning Services Financial planning fees may be invoiced up to fifty percent (50%) of the expected total fee upon execution of the financial planning agreement. The balance shall be invoiced upon completion of the agreed upon deliverable[s]. Investment Consulting Services Fees for investment consulting services are paid quarterly at the beginning of each calendar quarter. The amount due is calculated by applying the quarterly rate (annual rate divided by 4) to the total assets under advisement with the Advisor at the end of the prior quarter. Clients will be invoiced for investment consulting services and the fee shall be paid via Masso Torrence Wealth Management Inc. 270 N Elmwood Road, Suite H-160, Marlton, NJ 08053 Phone: (856) 988-6664 | Fax: (856) 861-1885 https://www.massotorrence.com  check made payable to the Advisor. Retirement Plan Advisory Services Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan, depending on the terms of the retirement plan advisory agreement. Third Party Money Managers In TPMM accounts, the TPMMs deducts the advisory fee from the client’s account and will forward a portion of the fee to the Adviser. Masso Torrence urges clients to refer to the selected TPMM’s disclosure documents for exact fees and expenses charged by each such TPMM, as well as minimum account requirements, refund, and termination provisions. A complete description of each program can be found in disclosure materials prepared by the TPMM, which we will provide to the client at the time we recommend the program. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than Masso Torrence, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian, as applicable. The Advisor's recommended Custodian does not charge securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets the terms and conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for mutual funds and other types of investments. The fees charged by Masso Torrence are separate and distinct from these custody and execution fees. In addition, all fees paid to Masso Torrence for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of Masso Torrence, but would not receive the services provided by Masso Torrence which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Masso Torrence to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Wealth Management Services/Investment Consulting Services Masso Torrence may be compensated for its services in advance of the quarter in which services are rendered. Either party may terminate the wealth management agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the wealth management or investment consulting agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the quarter. The Client’s wealth management agreement with the Advisor is non-transferable without the Client’s prior consent. Financial Planning Services Masso Torrence may require an advance deposit as described above. Either party may terminate the financial planning agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the financial planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Client shall be billed for actual hours logged on the planning project times the contractual hourly rate or in the case of a fixed fee engagement, the percentage of the engagement scope completed by the Advisor. Upon termination, the Advisor will refund any unearned, prepaid planning fees. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent. Masso Torrence Wealth Management Inc. 270 N Elmwood Road, Suite H-160, Marlton, NJ 08053 Phone: (856) 988-6664 | Fax: (856) 861-1885 https://www.massotorrence.com  Retirement Plan Advisory Services Masso Torrence is compensated for its retirement plan services. Fees may be in advance of or at the end of a calendar quarter or month. Either party may terminate the retirement plan advisory agreement, at any time, by providing advance written notice to the other party. The Client shall be responsible for retirement plan advisory fees up to and including the effective date of termination. Upon termination, the Advisor will refund any unearned, prepaid retirement plan advisory fees from the effective date of termination to the end of the quarter. The Client’s retirement plan advisory agreement with the Advisor is non-transferable without the Client’s prior consent. E. Compensation for Sales of Securities Masso Torrence does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. Advisory Persons are also licensed as independent insurance professionals. As an independent insurance professional, an Advisory Person may earn commission-based compensation for selling insurance products, including insurance products they sell to Clients. Insurance commissions earned by Advisory Persons are separate and in addition to our advisory fees. This practice presents a conflict of interest as the Advisory Person has an incentive to recommend insurance products to Clients for the purpose of generating commissions rather than solely based on your needs. Clients are under no obligation, contractually or otherwise, to purchase insurance products through any Advisory Person affiliated with the Advisor. Please see Item 10 below. Item 6 – Performance-Based Fees and Side-By-Side Management Masso Torrence does not charge performance-based fees for its investment advisory services. The fees charged by Masso Torrence are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. Masso Torrence does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients Masso Torrence offers investment advisory services to individuals, high net worth individuals, trusts, estates, retirement plans, and small businesses. Masso Torrence generally does not impose a minimum relationship size. However, accounts with less than $500,000 in assets under management are charged a fixed fee of $5,000 plus 0.30% annually Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis Masso Torrence primarily employs fundamental and technical analysis methods in developing investment strategies for its Clients. Research and analysis from Masso Torrence are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in Masso Torrence Wealth Management Inc. 270 N Elmwood Road, Suite H-160, Marlton, NJ 08053 Phone: (856) 988-6664 | Fax: (856) 861-1885 https://www.massotorrence.com  using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that Masso Torrence will be able to accurately predict such a reoccurrence. As noted above, Masso Torrence generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Masso Torrence will typically hold all or a portion of a security for more than a year but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Masso Torrence may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Masso Torrence will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. Please see Item 8.B. for risks associated with the Advisor’s investment strategies as well as general risks of investing. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment strategies: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Bond ETF Risks Bond ETFs are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may Masso Torrence Wealth Management Inc. 270 N Elmwood Road, Suite H-160, Marlton, NJ 08053 Phone: (856) 988-6664 | Fax: (856) 861-1885 https://www.massotorrence.com  not be sold as quickly as there is no readily available market for the bond. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Options Contract Risks Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock. This leverage can compound gains or losses. Margin Borrowing Risks The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if securities pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to a "margin call", pursuant to which it must either deposit additional funds with the broker or be the subject of mandatory liquidation of the pledged securities to compensate for the decline in value. Alternative Investment (Limited Partnerships) Risks The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An investor could lose all or a portion of their investment. Such investments often have concentrated positions and investments that may carry higher risks. Client should only have a portion of their assets in these investments. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory or disciplinary events involving Masso Torrence or its management persons. Masso Torrence values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor or Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 311097. Item 10 – Other Financial Industry Activities and Affiliations Insurance Agency Affiliations As noted in Item 5, Advisory Persons are also licensed insurance professionals. Implementations of insurance recommendations are separate and apart from one’s role with Masso Torrence. As an insurance professional, an Advisory Person may receive customary commissions and other related revenues from the various insurance companies whose products are sold. Advisory Persons are not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This may cause a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by an Advisory Persons or the Advisor. Selection of Other Investment Advisers The Adviser may recommend or select TPMMs to clients and receive compensation from the third-party via a fee share; thus, a material conflict of interest exists between the Adviser’s interests and those the clients in that the Adviser has an incentive to direct clients to TPMMs that provide us with a larger fee split. The Adviser will always act in the best interest of our clients when making recommendations or selecting TPMMs. The client always has the right to decide whether to act on our recommendations and whether to utilize the services of the recommended TPMM. The client always has the right to utilize the professional of his or her choice. All TPMMs will be properly licensed and registered as investment Masso Torrence Wealth Management Inc. 270 N Elmwood Road, Suite H-160, Marlton, NJ 08053 Phone: (856) 988-6664 | Fax: (856) 861-1885 https://www.massotorrence.com  advisers in the proper jurisdictions. The fees shared will not exceed any limit imposed by any regulatory agency. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Masso Torrence has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with Masso Torrence (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. Masso Torrence and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Masso Torrence’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (856) 988-6664. B. Personal Trading with Material Interest Masso Torrence allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Masso Torrence does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund or advise an investment company. Masso Torrence does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients Masso Torrence allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by Masso Torrence requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”). The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While Masso Torrence allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no time will Masso Torrence, or any Supervised Person of Masso Torrence, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Masso Torrence does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize Masso Torrence to direct trades to the Custodian as agreed upon in the wealth management agreement. Further, Masso Torrence does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. Where Masso Torrence does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the Custodian recommended by the Advisor and will not incur any extra fee or cost associated with using a custodian not recommended by Masso Torrence. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. Masso Torrence may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, its reputation, and/or the location of the Custodian’s offices. Masso Torrence will generally recommend that Clients establish their account[s] at Masso Torrence Wealth Management Inc. 270 N Elmwood Road, Suite H-160, Marlton, NJ 08053 Phone: (856) 988-6664 | Fax: (856) 861-1885 https://www.massotorrence.com  Charles Schwab & Co., Inc. (“Schwab”), a FINRA-registered broker-dealer and member SIPC. Schwab will serve as the Client’s “qualified custodian”. Masso Torrence maintains an institutional relationship with Schwab, whereby the Advisor receives economic benefits from Schwab. Please see Item 14 below. Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. Masso Torrence does not participate in soft dollar programs sponsored or offered by any broker- dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 below. 2. Brokerage Referrals - Masso Torrence does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Masso Torrence will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). Masso Torrence will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. Masso Torrence will execute its transactions through the Custodian as authorized by the Client. Masso Torrence may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by Advisory Persons of Masso Torrence and periodically by the CCO. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Masso Torrence if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with Masso Torrence Wealth Management Inc. 270 N Elmwood Road, Suite H-160, Marlton, NJ 08053 Phone: (856) 988-6664 | Fax: (856) 861-1885 https://www.massotorrence.com  periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by Masso Torrence Masso Torrence is a fee-based advisory firm, that is compensated solely by its Clients and not from any investment product. Masso Torrence does not receive commissions or other compensation from product sponsors, broker-dealers or any un-related third party. Masso Torrence may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, Masso Torrence may receive non-compensated referrals of new Clients from various third-parties. Participation in Institutional Advisor Platform Masso Torrence has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like Masso Torrence. As a registered investment advisor participating on the Schwab Advisor Services platform, Masso Torrence receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this custodian over one that does not furnish similar software, systems support, or services. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients but may not directly benefit all Clients. Services that May Only Benefit the Advisor – Schwab also offers other services and financial support to Masso Torrence that may not benefit the Client, including educational conferences and events, financial start-up support, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a conflict of interest. Masso Torrence believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. The Adviser has arrangements with TPMMs. The Adviser will receive compensation based on the service they provide to the clients. Any such compensation arrangement will be formalized in an agreement and disclosed to our clients. B. Client Referrals from Solicitors Masso Torrence engages and compensates unaffiliated third-party referral sources (a “Solicitor”) for Client referrals. Clients will not pay a higher fee to Masso Torrence as a result of such payments to a Solicitor. The Advisor shall enter into an agreement with the Solicitor, which requires that full disclosure of the compensation and other conflicts is provided to the prospective client prior to or at the time of entering into the advisory agreement. Item 15 – Custody Masso Torrence does not accept or maintain custody of any Client accounts, except for the authorized deduction of Masso Torrence Wealth Management Inc. 270 N Elmwood Road, Suite H-160, Marlton, NJ 08053 Phone: (856) 988-6664 | Fax: (856) 861-1885 https://www.massotorrence.com  the Advisor’s fees. All Clients must place their assets with a “qualified custodian”. Clients are required to engage the Custodian to retain their funds and securities and direct Masso Torrence to utilize that Custodian for the Client’s security transactions. Clients should review statements provided by the Custodian and compare to any reports provided by Masso Torrence to ensure accuracy, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. If the Client gives the Advisor authority to move money from one account to another account, the Advisor may have custody of those assets. In order to avoid additional regulatory requirements, the Custodian and the Advisor have adopted safeguards to ensure that the money movements are completed in accordance with the Client’s instructions. Item 16 – Investment Discretion Masso Torrence generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Masso Torrence. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of a wealth management agreement containing all applicable limitations to such authority. All discretionary trades made by Masso Torrence will be in accordance with each Client's investment objectives and goals. For non-discretionary accounts, Masso Torrence will contact the Client to obtain approval prior to executing trade[s] in the Account[s]. Item 17 – Voting Client Securities Masso Torrence does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Item 18 – Financial Information Neither Masso Torrence, nor its management, have any adverse financial situations that would reasonably impair the ability of Masso Torrence to meet all obligations to its Clients. Neither Masso Torrence, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. Masso Torrence is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. Masso Torrence Wealth Management Inc. 270 N Elmwood Road, Suite H-160, Marlton, NJ 08053 Phone: (856) 988-6664 | Fax: (856) 861-1885 https://www.massotorrence.com  Privacy Policy Effective: February 19, 2025 Our Commitment to You Masso Torrence Wealth Management Inc. (“Masso Torrence” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Masso Torrence (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Masso Torrence does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage and advisory agreements Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment questionnaires and suitability documents Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. Masso Torrence Wealth Management Inc. 270 N Elmwood Road, Suite H-160, Marlton, NJ 08053 Phone: (856) 988-6664 | Fax: (856) 861-1885 https://www.massotorrence.com  How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. No Not Shared Yes Yes No Not Shared Marketing Purposes Masso Torrence does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Masso Torrence or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. Information About Former Clients Masso Torrence does not disclose and does not intend to disclose, non- public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (856) 988-6664. Masso Torrence Wealth Management Inc. 270 N Elmwood Road, Suite H-160, Marlton, NJ 08053 Phone: (856) 988-6664 | Fax: (856) 861-1885 https://www.massotorrence.com