Meschel Wealth Management LLC

Item 1: Cover Page INFORMATIONAL BROCHURE MESCHEL WEALTH MANAGEMENT LLC 933 Pickering Drive 2nd Floor Yardley, PA 19067 (267) 573-0015 July 27, 2026 This brochure provides information about the qualifications and business practices of Meschel Wealth Management LLC. If you have any questions about the contents of this brochure, please contact David Meschel at the number listed above or via email at dave@meschelwm.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Meschel Wealth Management LLC is a registered investment adviser. Registration does not imply any certain level of skill or training. Additional information about Meschel Wealth Management LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. 1  Item 2: Material Changes Meschel Wealth Management LLC is required to update its Form ADV in the event of a material change. There are no material changes to report. 2  Item 3: Table of Contents Cover Page Item 1: 1 Material Changes Item 2: 2 Table of Contents Item 3: 3 Advisory Business Item 4: 4 Fees and Compensation Item 5: 5 Performance-Based Fees and Side-By-Side Management Item 6: 8 Types of Clients Item 7: 8 Methods of Analysis, Investment Strategies and Risk of Loss Item 8: 8 Disciplinary Information Item 9: 11 Other Financial Industry Activities and Affiliations Item 10: 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Item 11: 12 Brokerage Practices Item 12: 12 Review of Accounts Item 13: 15 Client Referrals and Other Compensation Item 14: 15 Custody Item 15: 16 Investment Discretion Item 16: 17 Voting Client Securities Item 17: 17 Financial Information Item 18: 17 3  INFORMATIONAL BROCHURE MESCHEL WEALTH MANAGEMENT LLC Item 4: Advisory Business The mission of Meschel Wealth Management LLC (“MWM”) is to provide investment advisory services to clients. MWM was established in 2020 and is principally owned by David G. Meschel. Prior to engaging MWM to provide investment advisory services, the client is required to enter into one or more written agreements with MWM setting forth the terms and conditions under which MWM renders its services (collectively the “Agreement”). Investment Management Services Clients can engage MWM to manage all or a portion of their assets on a discretionary basis. A discretionary engagement means MWM will have a Limited Power of Attorney to invest and reinvest the client’s assets in accordance with their investment objectives without consultation with the client prior to making a change in the portfolio. MWM allocates clients’ investment management assets among mutual funds and exchange-traded funds (“ETFs”). These allocations are done in accordance with the client’s overall investment objective. MWM also provides advice about any type of investment held in clients' portfolios. Clients are advised to promptly notify MWM if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon MWM’s management services. Clients may impose reasonable restrictions or mandates on the management of their account if, in MWM’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. Third Party Asset Management In certain circumstances, MWM may recommend or introduce Clients to an unaffiliated investment adviser or third-party manager. Prior to introducing a Client to another investment adviser, MWM will conduct reasonable due diligence to determine whether such adviser is properly registered, notice filed, or exempt from registration with the Pennsylvania Department of Banking and Securities or other applicable regulatory body. MWM may utilize SEI Private Trust Company as a third-party money manager. SEI will be the custodian for the client’s account(s). SEI has a mutual fund models program that utilizes their mutual funds to create model portfolios. If using the SEI mutual fund models program: o MWM will have discretionary authority to manage the account on the client’s behalf o MWM will select the mutual fund model in which to invest client funds and may change the mutual fund model that is utilized o MWM can instruct SEI to hold specific security positions in the client’s account SEI also provides a Managed Account Solutions option. If MWM utilizes the SEI Managed Account Solutions, then: 4  o SEI acts as co-investment advisor to the investor, along with MWM, pursuant to a tri-party investment management agreement executed among SEI, MWM and the client o SEI is solely responsible for screening, reviewing, and selecting the various money managers and/or individual mutual funds and other assets available for selection by MWM and the client designed to meet the specific Managed Account Portfolio’s stated investment objective or goal Financial Planning MWM does provide comprehensive financial planning services to clients under separate engagement. The planning process produces recommendations that the client can then implement or not implement at their discretion. Assets Under Management As of April 30, 2026 MWM has $107,462,176 in assets under management across 433 accounts, all managed on a discretionary basis. Item 5: Fees and Compensation Fees Charged A. Investment Management Fees MWM provides investment management services for an annual fee based upon a percentage of the market value of the assets being managed by MWM. MWM’s annual fee is exclusive of, and in addition to brokerage commissions, transaction fees, and other related costs and expenses which are incurred by the client. MWM does not, however, receive any portion of these commissions, fees, and costs. MWM’s annual fee is prorated and charged quarterly, in advance, based upon the market value of the assets being managed by MWM on the last day of the previous quarter/month. TIER PORTFOLIO VALUE BASE FEE 1 $0 - $250,000 1.25% 2 $250,001 - $500,000 1.00% 3 $500,001 - $1,000,000 0.90% 4 $1,000,001 - $2,500,000 0.60% 5 $2,500,001 - $5,000,000 0.40% 6 $5,000,000+ 0.25% The annual fee follows a tiered fee schedule as shown. Each increment of assets under management are charged the appropriate fee and then added together for a total fee to be charged to the account. For example, if your account value is $400,000 then the first $250,000 will have a fee of 1.25% and the next $150,000 will have a fee of 1.00%. Any changes to the fee charged cannot be made by MWM without the express consent of the client. MWM, in its sole discretion, may negotiate to charge a lesser management fee based upon certain criteria (i.e., anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be 5  managed, related accounts, account composition, pre-existing client, account retention, pro bono activities, etc.). Third Party Asset Management Client shall pay Adviser a quarterly fee, paid in advance, based upon the net market value of Client’s managed assets as of the last day of the prior quarter. The annual management fee is 1.25%. The custodian will deduct the fee from your account and remit it to MWM. In addition to the fees to Advisor, each manager charges ongoing management fees. These fees should not be confused with “loads” or commissions. Adviser does not receive any additional compensation, either directly or indirectly, from these managers. Various transaction fees to the Custodian or other brokerage firm associated with the custody, purchases and/or sales of assets in Client’s account will also be incurred. To the extent that your assets are allocated among independent third-party managers, the fees charged by such third-party managers are separate and in addition to the fees charged by Advisor. No portion of Adviser’s compensation shall be based upon a share of capital gains or appreciation of the assets or any portion of the assets. The aggregate fees charged to Clients, including both MWM’s fee and any third-party manager fees, will not exceed 3.00% of assets under management annually. Financial Planning Fees Fees for financial plans can be charged on either a fixed or hourly basis. Hourly fees do not exceed $350 per hour and fixed fees range from $1,500 to $5,000. Both hourly and fixed fees are negotiable based upon the actual services requested and the complexity of the client’s situation. If fees are charged on an hourly basis, MWM provides the client with an estimate of the hours needed to complete the requested plan. If more time is needed to complete the plan than the original estimate, MWM requests the permission of the client prior to proceeding with any additional work. The client is charged for the actual time expended on the plan. Both hourly and fixed fees are due upon presentation of the plan to the client and MWM provides the client with a detailed billing statement. Financial planning services terminate upon presentation of the plan to the client. However, either MWM or the client can terminate services at any time by providing written notice to the other party. Termination is effective immediately upon receiving the notice. If services are terminated within five business days of signing the financial planning agreement, services are terminated without penalty. The client is responsible for the time expended to the date of termination and MWM provides the client with a billing statement detailing the prorated charge due. Fee Payment B. For clients whose assets are managed by MWM, investment advisory fees will be debited directly from each client’s account. The advisory fee is paid quarterly, in advance, and the value used for the fee calculation is the net value as of the last market day of the previous quarter. To the extent there is cash in your account, it will be included in the value for the purpose of calculating fees. Once the calculation is made, MWM will instruct your account custodian to deduct the fee from your account and remit it to MWM. MWM does not send invoices to clients. 6  Clients whose fees are directly debited will provide written authorization to debit advisory fees from their accounts held by a qualified custodian chosen by the client. Each quarter, the client will receive a statement from their account custodian showing all transactions in their account, including the fee. Other Fees C. As further discussed in response to Item 12 (below), MWM generally recommends that clients utilize the brokerage, custodial, and clearing services of Schwab for investment management accounts. MWM may only implement its investment management recommendations after the client has arranged for and furnished MWM with all information and authorization regarding accounts with appropriate financial institutions. Financial institutions include, but are not limited to, Schwab, any other broker- dealer recommended by MWM, broker-dealer directed by the client, trust companies, banks, etc. (collectively referred to herein as the “Financial Institutions”). Clients may incur certain charges imposed by the Financial Institutions and other third parties such as fees charged by Independent Managers, custodial fees, charges imposed directly by a mutual fund or ETF in the account, which are disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Additionally, for assets outside of any wrap fee programs, clients may incur brokerage commissions and transaction fees. Such charges, fees and commissions are exclusive of and in addition to MWM’s fee. Pro-rata Fees D. For the initial period of investment management services, the fees are calculated on a pro rata basis. The Agreement between MWM and the client will continue in effect until terminated by either party pursuant to the terms of the Agreement. MWM’s fees are prorated through the date of termination and any remaining balance is charged or refunded to the client, as appropriate. Clients may make additions to and withdrawals from their account at any time, subject to MWM’s right to terminate an account. Additions may be in cash or securities provided that MWM reserves the right to liquidate any transferred securities or decline to accept particular securities into a client’s account. Clients may withdraw account assets on notice to MWM, subject to the usual and customary securities settlement procedures. However, MWM designs its portfolios as long-term investments, and the withdrawal of assets may impair the achievement of a client’s investment objectives. MWM may consult with its clients about the options and ramifications of transferring securities. However, clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, fees assessed at the mutual fund level (i.e. contingent deferred sales charge) and/or tax ramifications. MWM will cease to perform services, including processing trades and distributions, upon termination. Assets not transferred from terminated accounts within thirty (30) days of termination may be “de-linked”, meaning they will no longer be visible to MWM and will become a retail account with the custodian. E. Compensation for the Sale of Securities This item is not applicable. 7  Item 6: Performance-Based Fees and Side-By-Side Management MWM will not charge performance-based fees. Item 7: Types of Clients MWM provides its services to individuals, pension and profit-sharing plans, trusts, estates, charitable organizations, corporations and business entities. MWM does not have a specified minimum account size. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss It is important for clients to know and remember that all investments carry risks. Investing in securities involves risk of loss that clients should be prepared to bear. Methods of Analysis and Investment Strategies Each client’s portfolio is created through the evaluation of the client’s needs. Portfolio construction originates with an evaluation of each client’s investment objectives as well as the client’s risk tolerance. Both sources are part of developing a portfolio that takes into consideration the client’s investment horizons, ability, and desire to withstand the volatility that can come with investing, and overall goals for each specific portfolio. It is essential to MWM’s service that the process be a fully cooperative one, and therefore clients of all account sizes are advised to keep MWM informed of changes in financial circumstances, as these changes could affect the client’s asset allocation. Once an overall asset allocation is determined, MWM moves on to determine how best to implement that allocation, beginning with an assessment as to whether a passive or active approach is most likely to achieve the desired results. An active path would include the use of a managed account or mutual fund, where a manager makes active decisions for that account or fund. A passive example would be an exchange traded fund or mutual fund. In some instances, both active and passive routes may be taken in constructing a strategy’s holdings. The cost of each specific security, both in terms of price and expenses, is also considered when choosing specific securities. Part of the security selection process is also the consideration of what assets the client already has in the portfolio. Clients may come to MWM with a variety of investments, with a variety of custodians. Where possible and advisable, MWM will advise the transfer of assets in-kind, meaning the asset will not be sold before the account is moved to the custodian under MWM’s advisement. Some securities may be kept in the portfolio because of tax issues or other costs associated with a transition. To the extent these securities are not sold, MWM will attempt to build a portfolio taking these securities into consideration and advise the client if there are additional risks associated with keeping a specific security. In the use of mutual funds, MWM utilizes the lowest cost share class the client is eligible for. Risk of Loss 8  There are always risks to investing. Clients should be aware that all investments carry various types of risk, including the potential loss of principal that clients should be prepared to bear. It is impossible to name all possible types of risks. Among the risks are the following: MWM’s primary strategies do not include frequent trading of securities. It is impossible to name all possible types of risks. Among the risks are the following: • POLITICAL RISKS. Most investments have a global component, even domestic stocks. Political events anywhere in the world may have unforeseen consequences to markets around the world. • CLIENT PARTICIPATION. Because MWM uses information from clients in determining the appropriate asset allocations for each portfolio or account, having up to date and accurate information from the client is imperative. Changes in circumstances that are not reported to MWM in a timely manner can materially and adversely affect MWM’s ability to meet the client’s needs. • GENERAL MARKET RISKS. Markets can, as a whole, go up or down on various news releases or for no understandable reason at all. This sometimes means that the price of specific securities could go up or down without real reason and may take some time to recover any lost value. Adding additional securities does not help to minimize this risk since all securities may be affected by market fluctuations. • CURRENCY RISK. When investing in another country using another currency, the changes in the value of the currency can change the value of your security value in your portfolio. • REGULATORY RISK. Changes in laws and regulations from any government can change the value of a given company and its accompanying securities. Certain industries are more susceptible to government regulation. Changes in zoning, tax structure or laws impact the return on these investments. • TAX RISKS RELATED TO SHORT TERM TRADING. Clients should note that while MWM does not consider short-term trading a strategy for its clients, trades may be made with frequency if conditions and client goals merit it. These transactions may result in short term gains or losses for federal and state tax purposes, which may be taxed at a higher rate than long term strategies. MWM endeavors to invest client assets in a tax efficient manner, but all clients are advised to consult with their tax professionals regarding the transactions in client accounts. • PURCHASING POWER RISK. Purchasing power risk is the risk that your investment’s value will decline as the price of goods rises (inflation). The investment’s value itself does not decline, but its relative value does, which is the same thing. Inflation can happen for a variety of complex reasons, including a growing economy and a rising money supply. • BUSINESS RISK. This can be thought of as certainty or uncertainty of income. Management comes under business risk. Cyclical companies (like automobile companies) have more business risk because of the less steady income stream. On the other hand, fast food chains tend to have steadier income streams and therefore, less business risk. • FINANCIAL RISK. The amount of debt or leverage determines the financial risk of a company. • DEFAULT RISK. This risk pertains to the ability of a company to service their debt. Ratings provided by several rating services help to identify those companies with more risk. Obligations of the U.S. government are said to be free of default risk. • MARGIN RISK. “Margin” is typically used to maximize returns on a given investment by using securities in a client account as collateral for a loan from the custodian to the client. The proceeds of that loan are then used to buy more securities. In a positive result, the additional securities provide additional return on the same initial investment. In a negative result, the additional securities provide additional losses. Margin, therefore, carries a higher degree of risk than investing without margin. Any client account that will use margin will do so in accordance with Regulation T. MWM does not recommend the use of margin as part of its portfolio construction process. However, clients may on occasion wish to utilize margin to facilitate some other need or goal. In these cases, the margin will increase the value of 9  the assets in the account, which means the management fees calculated, which are based on account value, will also increase. • INFORMATION RISK. All investment professionals rely on research in order to make conclusions about investment options. This research is always a mix of both internal (proprietary) and external (provided by third parties) data and analyses. Even an advisor who says they rely solely on proprietary research must still collect data from third parties. This data, or outside research is chosen for its perceived reliability, but there is no guarantee that the data or research will be completely accurate. Failure in data accuracy or research will translate to a compromised ability by the advisor to reach satisfactory investment conclusions. • SMALL COMPANIES. Some investment opportunities in the marketplace involve smaller issuers. These companies may be starting up or are historically small. While these companies sometimes have potential for outsized returns, they also have the potential for losses because the reasons the company is small are also risks to the company’s future. For example, a company’s management may lack experience, or the company’s capital for growth may be restricted. These small companies also tend to trade less frequently than larger companies, which can add to the risks associated with their securities because the ability to sell them at an appropriate price may be limited as compared to the markets as a whole. Not only do these companies have investment risk, if a client is invested in such small companies and requests immediate or short-term liquidity, these securities may require a significant discount to value in order to be sold in a shorter time frame. • CONCENTRATION RISK. While MWM selects individual securities, including mutual funds, for client portfolios based on an individualized assessment of each security, this evaluation comes without an overlay of sector specific issue analysis. This means that a client’s equity portfolio may be concentrated in a specific sector, geography, or sub-sector (among other types of potential concentrations), so that if an unexpected event occurs that affects that specific sector or geography, for example, the client’s equity portfolio may be affected negatively, including significant losses. • TRANSITION RISK. As assets are transitioned from a client’s prior advisors to MWM, there may be securities and other investments that do not fit within the asset allocation strategy selected for the client. Where possible, MWM will maintain securities that come from the client’s existing accounts and will not sell a security merely to push the portfolio into line with other accounts MWM manages. However, in some instances, selling a security is advisable despite costs. MWM’s goal is to minimize costs, which means that the overall transition process to MWM may take some time as cost considerations are compared with client needs. Some investments may not be unwound for a lengthy period of time for a variety of reasons that may include unwarranted low share prices, restrictions on trading, contractual restrictions on liquidity, or market-related liquidity concerns. In some cases, there may be securities or investments that are never able to be sold. The inability to transition a client's holdings into the client's account values, as MWM’s recommendations of MWM may adversely affect recommendations may not be able to be fully implemented. • RESTRICTION RISK. Clients may at all times place reasonable restrictions on the management of their accounts. However, placing these restrictions may make managing the accounts more difficult, thus lowering the potential for returns. In addition, significant restrictions may lead to MWM needing to increase the management fee rate. • RISKS RELATED TO INVESTMENT TERM & LIQUIDITY. Securities do not follow a straight line up in value. All securities will have periods of time when the current price of the security is not an accurate measure of its value. If you require us to liquidate your portfolio during one of these periods, you will not realize as much value as you would have had if the investment had the opportunity to regain its value. Further, some investments are made with the intention of the investment appreciating over an extended period of time. Liquidating these investments prior to their intended time horizon may result in losses. 10  Security Types As discussed above, MWM recommends mutual funds and ETFs. However, MWM may utilize stocks or bonds. Methods of Analysis MWM’s primary method of analysis incorporates aspects of both quantitative research and fundamental analysis. The quantitative research process involves the analysis of historic returns and risk (volatility) for various asset classes as well as correlations between assets classes. Quantitative analysis helps to measure, evaluate, compare, and value different investment opportunities with the goal of improving risk adjusted returns. The primary risk in using quantitative analysis is that historical data and trends alone may not fully explain past results. In addition, there is ample evidence that proves that past trends and returns do not necessarily predict future events. Further, even if a trend will eventually reoccur, there is no guarantee that MWM will be able to accurately predict such a reoccurrence. Qualitative or fundamental analysis involves a review of financial condition and competitive positioning. Examples of factors that MWM considers include strength, experience, and credibility of management and key personnel, risk controls, technology, and infrastructure to support their investment process, and succession planning. The primary risk in using this type of analysis is that while the overall health and position of a company may be good, market conditions may negatively impact the security. Securities in the investment strategy may be exchanged and/or transferred without regard to a client’s individual tax ramifications. Certain investment opportunities that become available to MWM’s clients may be limited. As further discussed in response to Item 12B (below), MWM allocates investment opportunities among its clients on a fair and equitable basis. Item 9: Disciplinary Information There are no disciplinary items to report. Item 10: Other Financial Industry Activities and Affiliations A. Broker-dealer This item is not applicable. B. Futures Commission Merchant/Commodity Trading Advisor Neither the principal of MWM, nor any related persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. C. Relationship with Related Persons Neither the principal of MWM, nor any related person have any material relationships to this advisory business that would present a possible conflict of interest. 11  D. Recommendations of Other Advisers MWM does not recommend other advisers. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A copy of our Code of Ethics is available upon request. Our Code of Ethics includes discussions A. of our fiduciary duty to clients, political contributions, gifts, entertainment, and trading guidelines. MWM does not recommend to clients that they invest in any security in which MWM, or any B. principal thereof, has any financial interest. C. On occasion, an employee of MWM may purchase for his or her own account securities which are also recommended for clients. Our Code of Ethics details rules for employees regarding personal trading and avoiding conflicts of interest related to trading in one’s own account. To avoid placing a trade before a client (in the case of a purchase) or after a client (in the case of a sale), all employee trades must be reviewed by the Compliance Officer. All employee trades must either take place in the same block as a client trade or sufficiently apart in time from the client trade so the employee receives no added benefit. Employee statements are reviewed to confirm compliance with the trading procedures. D. On occasion, an employee of MWM may purchase for his or her own account securities which are also recommended for clients at the same time the clients purchase the securities. Our Code of Ethics details rules for employees regarding personal trading and avoiding conflicts of interest related to trading in one’s own account. To avoid placing a trade before a client (in the case of a purchase) or after a client (in the case of a sale), all employee trades must be reviewed by the Compliance Officer. All employee trades must either take place in the same block as a client trade or sufficiently apart in time from the client trade so the employee receives no added benefit. Employee statements are reviewed to confirm compliance with the trading procedures. Item 12: Brokerage Practices Recommendation of Broker-Dealer A. MWM does not maintain custody of client assets; though MWM may be deemed to have custody if a client grants MWM authority to debit fees directly from their account (see Item 15 below). Assets will be held with a qualified custodian, which is typically a bank or broker-dealer. MWM recommends that investment accounts be held in custody by Schwab, which is a qualified custodian. MWM is independently owned and operated and is not affiliated with Schwab. Schwab will hold your assets in a brokerage account and buy and sell securities when MWM instructs them to, which MWM does in accordance with its agreement with you. While MWM recommends that you use Schwab as custodian/broker, you will decide whether to do so and will open your account with Schwab by entering into an account agreement directly with them. MWM does not open the account for you, although MWM may assist you in doing so. Even though your account is maintained at Schwab, we may use other brokers to execute trades for your account as described below (see “Your brokerage and custody costs”). 12  How we select brokers/custodians We seek to recommend a custodian/broker that will hold your assets and execute transactions on terms that are, overall, most beneficial when compared with other available providers and their services. We consider a wide range of factors, including both quantitative (Ex: costs) and qualitative (execution, reputation, service) factors. We do not consider whether Schwab or any other broker-dealer/custodian, refers clients to MWM as part of our evaluation of these broker-dealers. Your brokerage and custody costs For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. In addition to commissions, Schwab charges you a flat dollar amount as a “prime broker” or “trade away” fee for each trade that we have executed by a different broker- dealer but where the securities bought or the funds from the securities sold are deposited (settled) into your Schwab account. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. Because of this, in order to minimize your trading costs, we have Schwab execute most trades for your account. We have determined that having Schwab execute most trades is consistent with our duty to seek “best execution” of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see “How we select brokers/custodians”). Products and services available to us from Schwab Schwab Advisor Services™ (formerly called Schwab Institutional®) is Schwab’s business serving independent investment advisory firms like MWM. They provide MWM and our clients with access to its institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help MWM manage or administer our clients’ accounts, while others help MWM manage and grow our business. Schwab’s support services are generally available on an unsolicited basis (we don’t have to request them) and at no charge to MWM. Following is a more detailed description of Schwab’s support services: Services that benefit you Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Services that may not directly benefit you. Schwab also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or a substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: 13  • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients’ accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only us. Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology, compliance, legal, and business needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Assistance related to the transition of client assets from prior firms Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide us with other benefits, such as occasional business entertainment of our personnel. Our interest in Schwab’s services The availability of these services from Schwab benefits us because we do not have to produce or purchase them. We don’t have to pay for Schwab’s services. These services are not contingent upon us committing any specific amount of business to Schwab in trading commissions or assets in custody. We may have an incentive to recommend that you maintain your account with Schwab, based on our interest in receiving Schwab’s services that benefit our business rather than based on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a potential conflict of interest. We believe, however, that our selection of Schwab as custodian and broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services (see “How we select brokers/ custodians”) and not Schwab’s services that benefit only us. We do not consider whether Schwab or any other broker-dealer/custodian, refers clients to MWM as part of our evaluation of these broker-dealers. Aggregating Trades B. Transactions for each client generally will be affected independently, unless MWM decides to purchase or sell the same securities for several clients at approximately the same time. MWM may (but is not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable 14  commission rates, or to allocate equitably among MWM client’s differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will generally be averaged as to price and allocated among MWM’s clients pro rata to the purchase and sale orders placed for each client on any given day. To the extent that MWM determines to aggregate client orders for the purchase or sale of securities, including securities in which MWM’s Supervised Persons may invest, MWM generally does so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the U.S. Securities and Exchange Commission. MWM does not receive any additional compensation or remuneration as a result of the aggregation. In the event that MWM determines that a prorated allocation is not appropriate under the particular circumstances, the allocation will be made based upon other relevant factors, which may include: (i) when only a small percentage of the order is executed, shares may be allocated to the account with the smallest order or the smallest position or to an account that is out of line with respect to security or sector weightings relative to other portfolios, with similar mandates; (ii) allocations may be given to one account when one account has limitations in its investment guidelines which prohibit it from purchasing other securities which are expected to produce similar investment results and can be purchased by other accounts; (iii) if an account reaches an investment guideline limit and cannot participate in an allocation, shares may be reallocated to other accounts (this may be due to unforeseen changes in an account’s assets after an order is placed); (iv) with respect to sale allocations, allocations may be given to accounts low in cash; (v) in cases when a pro rata allocation of a potential execution would result in a de minimis allocation in one or more accounts, MWM may exclude the account(s) from the allocation; the transactions may be executed on a pro rata basis among the remaining accounts; or (vi) in cases where a small proportion of an order is executed in all accounts, shares may be allocated to one or more accounts on a random basis. Item 13: Review of Accounts For those clients to whom MWM provides investment management services, MWM monitors those portfolios as part of an ongoing process while regular account reviews are conducted on at least an annual basis. For those clients to whom MWM provides financial planning and/or consulting services, reviews are conducted on an “as needed” basis. All investment advisory clients are encouraged to discuss their needs, goals, and objectives with MWM and to keep MWM informed of any changes thereto. MWM contacts ongoing investment advisory clients at least annually to review its previous services and/or recommendations and to discuss the impact resulting from any changes in the client’s financial situation and/or investment objectives. Item 14: Client Referrals and Other Compensation A. Economic Benefit Provided by Third Parties for Advice Rendered to Client. Please refer to Item 12, where we discuss recommendation of Broker-Dealers. B. Compensation to Non-Advisory Personnel for Client Referrals. If a client is introduced to MWM by a party who is not a current client (a “Promoter”), MWM may pay the Promoter cash compensation in accordance with the requirements of Rule 206(4)-1 of the Investment Advisers Act of 1940, and any corresponding state securities law requirements. Any such fee provided for endorsements shall be paid solely from MWM’s investment management fee and shall not result in any additional charge to the client. If the client is introduced to MWM by a Promoter, MWM shall disclose 15  the nature of the endorsement relationship, and shall provide each prospective client with a copy of this Part 2. Because SmartAsset is not affiliated with MWM, and does not receive a greater fee from MWM for more client leads (MWM pays SmartAsset Advisors LLC a monthly subscription fee, which is the same regardless of the amount of generated leads or client engagements), MWM does not see any material conflicts of interest. Item 15: Custody MWM does not maintain custody of client assets; though MWM may be deemed to have custody through the use of third party standing letters of authorization (“SLOAs”), or if a client grants MWM authority to debit fees directly from their account. Assets will be held with a qualified custodian, which is typically a bank or broker-dealer. Please refer to Item 12, Brokerage Practices, for more information on our recommended qualified custodian. MWM may, at the Client’s direction, facilitate the transfer of funds from a Client account to a third party pursuant to an SLOA. As of December 31, 2025, MWM maintained SLOAs for 32 Clients in accounts totaling $27,891,903. MWM relies on regulatory guidance that provides that an investment adviser will not be deemed to have custody of client assets solely as a result utilizing SLOAs, provided that certain safeguards are satisfied. The safeguards include but are not limited to the following: 1. In writing, the client provides an instruction to the qualified custodian that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. 2. In writing, the client authorized the investment adviser, either on the qualified custodian’s form or separately, to direct transfers to the third party on a specified schedule or from time to time. 3. The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization, and provides a transfer of funds notice to the client promptly after each transfer. 4. The client can terminate or change the instruction to the client’s qualified custodian. 5. The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction. 6. The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. 7. The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. MWM’s Agreement and/or the separate agreement with any Financial Institution may authorize MWM through such Financial Institution to debit the client’s account for the amount of MWM’s fee and to directly remit that management fee to MWM in accordance with applicable custody rules. The Financial Institutions recommended by MWM have agreed to send a statement to the client, at least quarterly, indicating all amounts disbursed from the account including the amount of management fees 16  paid directly to MWM. In addition, as discussed in Item 13, MWM also sends periodic supplemental reports to clients. Clients should carefully review the statements sent directly by the Financial Institutions and compare them to those received from MWM. Item 16: Investment Discretion MWM is given the authority to exercise discretion on behalf of clients. MWM is considered to exercise investment discretion over a client’s account if it can affect transactions for the client without first having to seek the client’s consent. MWM is given this authority through a power-of-attorney included in the agreement between MWM and the client. Clients may request a limitation on this authority (such as certain securities not to be bought or sold). MWM takes discretion over the following activities: The securities to be purchased or sold; The amount of securities to be purchased or sold; When transactions are made; and The Independent Managers to be hired or fired. • • • • Item 17: Voting Client Securities MWM does not vote proxies on behalf of its clients. Clients receive proxies directly from the Financial Institutions where their assets are custodied and may contact MWM with questions about any such issuer solicitations. Item 18: Financial Information MWM does not require the prepayment of fees more than six (6) months or more in advance and therefore has not provided a balance sheet with this brochure. There are no material financial circumstances or conditions that would reasonably be expected to impair our ability to meet our contractual obligations to our clients 17