Overview

Assets Under Management: $200 million
High-Net-Worth Clients: 91
Average Client Assets: $3 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals

Fee Structure

Primary Fee Schedule (PART 2A)

MinMaxMarginal Fee Rate
$0 and above 0.75%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $7,500 0.75%
$5 million $37,500 0.75%
$10 million $75,000 0.75%
$50 million $375,000 0.75%
$100 million $750,000 0.75%

Clients

Number of High-Net-Worth Clients: 91
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 91.40
Average High-Net-Worth Client Assets: $3 million
Total Client Accounts: 476
Discretionary Accounts: 472
Non-Discretionary Accounts: 4

Regulatory Filings

CRD Number: 299798
Last Filing Date: 2024-10-10 00:00:00
Website: https://modelwealth.com

Form ADV Documents

Primary Brochure: PART 2A (2025-05-21)

View Document Text
Item 1 – Cover Page MODEL WEALTH, INC. Form ADV Part 2A FIRM BROCHURE Mailing Address: 1755 S. Naperville Road, Suite 100 Wheaton, IL 60189 (630) 381-1170 www.modelwealth.com May 20, 2025 This brochure provides information about the qualifications and business practices of Model Wealth, Inc. If you have any questions about this brochure, please contact us at (630) 381-1170 or letschat@modelwealth.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or by any state securities authority. Model Wealth, Inc. is a registered investment advisor. Registration of an Investment Advisor does not imply any level of skill or training. Additional Information about Model Wealth, Inc. is available on the SEC’s website at www.advisorinfo.sec.gov. Item 2 – Material Changes Model Wealth, Inc. (“Model Wealth”, the “Firm”, “we”, or “us”) is required to file with the United States Securities and Exchange Commission an updated version of ADV within 90 days of the end of the Firm’s fiscal year. We will ensure that you will receive updated Brochures with a summary of materials changes within 120 days of the close of our business’ fiscal year. We may further provide other ongoing disclosure information about material changes as necessary. Annual Update Model Wealth is required to advise you of any material changes to the Firm Brochure (ADV 2A) from our last annual update. Since our last amendment filing on 03/31/2025, we have the following material changes to disclose: Amendment – 5/20/2025  Item 4: We’ve updated our address, as Model Wealth no longer has a physical office. Our new mailing address is: 1755 S. Naperville Road, Suite 100, Wheaton, IL 60189. Previous Amendments: Annual Amendment – 3/31/2025     Item 4: “Advisory Business” has been amended to disclose the addition of Separately Managed Accounts / Turnkey Asset Management Programs with Vanguard Personalized Indexing Management, LLC. (“VPIM”) and continuing our relationship with Betterment for Advisors, LLC. Item 5: “Fees and Compensation” has been amended to disclose a change in Wealth Management Fees to $1,000 to $50,000 (from previously $6,000 to $50,000). Item 5: “Fees and Compensation” has been amended to remove percentage based advisory fees being assessed at Betterment from Donovan Sanchez’s (formerly of Skyview Wealth Management) clients. This is to better align with Model Wealth’s flat fee wealth management services. Item 5: “Fees and Compensation” has also been amended to disclose fees charged by Vanguard Personalized Indexing Management, LLC. (“VPIM”) and Betterment for Advisors, LLC. Amendment – 10/01/2024  Updated address to reflect our new mailing address. Our previous physical / mailing address was 55 S. Main St., Suite 380, Naperville, IL 60540 and our new mailing address only is 50 S. Main St., Suite 200, Naperville, IL 60540. Annual Amendment – 3/18/2024    Item 5: “Fees and Compensation” has been amended to disclose an increase in Wealth Management fees to $6,000 to $50,000 (from $6,000 to $18,000). Item 10: “Other Financial Industry Activities and Affiliations” has been amended to remove Alex Offerman from the Board of Directors with the Financial Planning Association of Illinois as his tenure officially ended on 12/31/2023. Item 12: “Brokerage Practices” has been amended to disclose the removal of TD Ameritrade Institutional and addition of Charles Schwab & Co, Inc. (“Schwab Advisor Services.”) MODEL WEALTH, INC. ADV PART 2A Page 2 of 12 At any time, you may view the current Brochure on-line at the SEC’s Investment Adviser Public Disclosure website (www.adviserinfo.sec.gov). You may also request a copy of this Brochure at any time by contacting us at (630) 381-1170 or letschat@modelwealth.com. MODEL WEALTH, INC. ADV PART 2A Page 2 of 12 Item 3 – Table of Contents Item 1: Cover Page .................................................................................................................................... 1 Item 2: Material Changes ......................................................................................................................... 2 Item 3: Table of Contents ......................................................................................................................... 4 Item 4: Advisory Business ........................................................................................................................ 5 Item 5: Fees and Compensation ................................................................................................................ 7 Item 6: Performance-Based Fees and Side-By-Side Management ........................................................... 9 Item 7: Types of Clients ............................................................................................................................ 9 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss .................................................... 9 Item 9: Disciplinary Information ............................................................................................................ 10 Item 10: Other Financial Industry Activities and Affiliations ................................................................ 10 Item 12: Brokerage Practices .................................................................................................................. 11 Item 13: Review of Accounts ................................................................................................................. 12 Item 14: Client Referrals and Other Compensation ................................................................................ 12 Item 15: Custody ..................................................................................................................................... 13 Item 16: Investment Discretion ............................................................................................................... 13 Item 17: Voting Clients Securities .......................................................................................................... 13 Item 18: Financial Information ............................................................................................................... 13 MODEL WEALTH, INC. ADV PART 2A Page 3 of 12 Item 4: Advisory Business Model Wealth, Inc. was incorporated under the laws of Illinois in May 2012. Randall T. Bruns, President, and Alex C. Offerman, Chief Compliance Officer, are the principals of Model Wealth. Model Wealth is a fully virtual comprehensive fee-only financial planning and wealth management services that include investment advice to individuals, families, estates, and trusts. These services are provided under two distinct arrangements: (1) Financial Planning Engagements (hourly or project-based) and (2) Wealth Management Relationships that include ongoing financial planning and investment management for a flat annual fee. Financial Planning Engagements (Hourly or Project-Based) Under Financial Planning Engagements, Clients engage Model Wealth to achieve a specific financial goal or develop a comprehensive financial plan for an hourly- or project-based fee. Model Wealth may address some or all the areas noted below in service of client goals: a. Asset Allocation b. Cash Flow Planning and Management c. Education Funding d. Estate Planning and Asset Titling e. Investment Portfolio Review f. Investment Management g. Risk Planning h. Retirement Planning i. Social Security j. Stock Option/Restricted Stock Planning k. Tax Planning At the outset of any engagement, Model Wealth conducts a review of a client’s financial situation to determine first whether the client needs Model Wealth’s services and, only then, how best to fulfill that need. It is Model Wealth’s intent under this arrangement to have no financial interest beyond the scope of work itself. This is especially true when asset management is not needed or when financial incentives are otherwise in direct conflict with the most optimal advice. Wealth Management Relationships Model Wealth’s Wealth Management program delivers portfolio management and financial planning in a simple, straightforward arrangement for a flat annual fee. This program is best suited for individuals needing both portfolio management and financial planning on an ongoing basis, and in scenarios that cannot effectively be satisfied with less frequent hourly based advice and simpler investment solutions. Wealth Management Relationships typically begin only after a financial planning engagement has been completed. This allows for all parties to determine if an ongoing Wealth Management Relationship is warranted. MODEL WEALTH, INC. ADV PART 2A Page 4 of 12 Wealth Management Relationships include the following: a. Regularly scheduled check-ups for your entire financial life. b. Complete portfolio oversight across all your accounts in one highly efficient strategy. c. Access to rebalancing software which helps us manage your portfolio for optimal balance and a close eye on taxes. d. A digital portal that tracks your inflows, outflows, investment returns, and allocations for every account you own. e. Online access to financial planning software to organize your entire financial life under one convenient login. f. Collaboration with CPAs, attorneys, insurance agents, bankers and any other professionals helping you manage your finances. All client portfolios are in accounts are held at an independent qualified custodian. Model Wealth constructs portfolios based on the client’s stated goals and risk tolerance. Clients can impose reasonable restrictions on the management of their account, including the ability to instruct Model Wealth not to purchase certain securities or types of securities. Clients must provide these restrictions to Model Wealth in writing. Discretionary and Non-Discretionary Wealth Management For the ongoing management of a client’s account, the client will authorize Model Wealth with discretionary or non-discretionary investment management authority. Most clients authorize Model Wealth with discretionary investment management authority. This means that Model Wealth will have the authority to place trades in a client’s account without prior consent by the client. However, certain clients may have restrictions from their employers or involvement with publicly traded companies, requiring trades to be approved before they are submitted, meaning that their accounts will be managed on a non-discretionary basis. Wrap Fee Programs Model Wealth does not participate in any wrap fee investment management programs. ADV Client Delivery If a client does not receive an ADV Part 2 at least 48 hours prior to entering into an advisory agreement, the client has a right to terminate the contract without penalty within five business days after entering into the contract. Otherwise, the client or Model Wealth may terminate the agreement with written notice to the other party at least fourteen (14) calendar days in advance. Assets Under Management As of December 31, 2024, Model Wealth managed approximately $286,110,200 of client assets. This includes approximately $281,176,200 of discretionary assets and $4,934,000 of non- discretionary assets. Separately Managed Accounts (“SMA”) and Turnkey Asset Management Programs (“TAMP”) Model Wealth may allocate (and/or recommend that the client allocate a portion of a client’s investment assets among unaffiliated separately managed accounts (“SMAs”) and/or independent investment managers in accordance with the client’s designated investment objective(s). In such situations, the SMA or independent investment managers shall have day-to-day responsibility for the active discretionary management of the allocated assets, including, to the extent applicable, MODEL WEALTH, INC. ADV PART 2A Page 6 of 13 proxy voting responsibility. Model Wealth shall continue to render investment supervisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Factors which Model Wealth shall consider in recommending SMAs or independent investment managers include the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, fees, and research. The investment management fee charged by the Independent Manager(s) is separate from, and in addition to, Model Wealth’s investment advisory fee as set forth in Item 5 below and which will be disclosed to the client before entering into the Independent Manager engagement and/or subject to the terms and conditions of a separate agreement between the client and the Independent Manager(s). Alex Offerman and Randall Bruns remains available to address any questions that a client or prospective client may have regarding the allocation of account assets to an Independent Manager(s), including the specific additional fee to be charged by such Independent Manager(s). As of this annual amendment, Model Wealth currently uses two independent managers which include Betterment for Advisors and Vanguard Personalized Indexing Management, LLC (“VPIM”). Betterment for Advisors, a division of Betterment LLC (herein “Betterment”) is what is often termed a “robo-advisor,” an online wealth management service that provides automated, algorithm-based portfolio management. Vanguard Personalized Indexing Management, LLC (“VPIM”) which provides “Direct Indexing” solutions to our clients. Item 5: Fees and Compensation The specific fees charged by Model Wealth are established in a client’s written agreement with Model Wealth and depend upon the nature of the engagement and the services rendered. Fees are negotiable at Model Wealth’s sole discretion. Financial Planning Fees Clients engage Model Wealth initially to provide services on specific tasks or to evaluate their financial situation and provide a comprehensive financial plan without an ongoing relationship. Under those circumstances, Model Wealth will either bill specifically by the hour or will quote a fixed fee based upon an estimate of the amount of time involved to provide that service. Model Wealth’s current hourly rate is $350, which may change from time to time. Hourly based fees are due upon completion of the work involved. At the outset of project-based engagements, one half of the agreed upon fee is due. The remainder of the fee is payable on the delivery of the plan or completion of the service. Clients can terminate the agreement, and Model Wealth will refund any unearned portion of the fee, which is determined at Model Wealth’s sole discretion. Following the delivery of the plan or the completion of the service, clients can seek out clarification from Model Wealth for a period of 30 days without incurring a charge; thereafter, clients can, from time to time, seek out the guidance and advice of Model Wealth regarding revisions and implementation at the then current hourly rate. Clients can pay these fees via check or credit card. MODEL WEALTH, INC. ADV PART 2A Page 7 of 13 Wealth Management Fee Model Wealth provides ongoing financial planning and investment management services for a flat annual fee. Model Wealth bases this fee on the scope of the services that the client needs and the complexity of the client’s overall financial situation. The fee is generally billed quarterly and may be paid either in advance or in arrears depending on the client’s specific custodian and/or investment manager. The foregoing terms are agreed to in the wealth management agreement signed by client and Model Wealth in advance of any work being completed by the firm. Alternatively, Model Wealth may enter an agreement with clients to charge a percentage-based fee not to exceed 0.75% of the client’s total portfolio value where the size of a client’s portfolios could make the annual flat fee excessive. Under these circumstances, the fee will not exceed what would otherwise be charged in an annual flat fee arrangement. Pre-existing advisory clients are charged advisory fees in effect at the time the client entered in the advisory relationship. Therefore, there are clients with advisory fees that may differ from those described above. Betterment for Advisors Betterment for Advisors Fees will be deducted directly from accounts held by the custodian. Betterment for Advisors Fees are payable quarterly, in arrears, for the previous calendar quarter. The fee is currently 0.15% but is subject to a maximum annual fee of 0.50%. This fee is in addition to the Model Wealth’s management fee. Additional information relating to the Betterment for Advisors Fee may be obtained in their Disclosure Brochure. Vanguard Personalized Investment Management (“VPIM”) Vanguard Personalized Investment Management Fees will be deducted directly from accounts held by the qualified custodian (Charles Schwab). VPIM fees are payable quarterly, in advance, for the upcoming calendar quarter based upon the previous quarter-end average balance. The fee is currently tiered and has a maximum annual fee of 0.20%. This fee is in addition to the Model Wealth’s management fee. Additional information relating to the VPIM Fee may be obtained in their Disclosure Brochure. Fee Billing Clients can choose to pay the Wealth Management annual fee via check, or have it debited directly from their account kept at an independent custodian. As client situations change, Model Wealth may recalculate its fee. However, no increase in the annual fee will be effective without the client’s prior consent and right to terminate the engagement. Accounts initiated or terminated during the quarter will be charged a pro-rated fee based on the amount of time remaining in the billing period. Upon termination, Model Wealth will refund any prepaid fees based on the amount time remaining in the billing period. Other Fees and Expenses Clients may incur fees from the custodian selected to provide services related to record keeping, tax reporting and statement production. These fees may include IRA and retirement account annual fees, nominal trade ticket charges or banking fees. Clients may also incur fees and expenses charged by mutual funds or exchange traded funds, which are described more thoroughly in each fund’s prospectus, and can include management fees and other expenses. No portion of any of the fees described above is retained by or remitted to Model Wealth. MODEL WEALTH, INC. ADV PART 2A Page 8 of 13 Clients who choose to pay Model Wealth’s fees via credit card may incur a transaction fee depending upon the policy of their credit card company. Item 6: Performance-Based Fees and Side-By-Side Management Model Wealth does not charge any performance-based fees or fees related to side-by-side management. Item 7: Types of Clients Model Wealth’s clients are primarily individuals, high net worth individuals, families, pension and profit-sharing plans, trusts, estates, charitable organizations, and small businesses. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Model Wealth believes that investments should be managed passively and implemented with cost- effectiveness and tax-efficiency in mind. Our investment strategy begins with a general long-term acceptance of the Efficient Market Hypothesis, which states that the primary driver of a portfolio’s risk and return characteristics is determined by asset allocation and not security selection. As countless studies have proven, active management underperforms the market. Model Wealth believes that selecting investments or investment managers that will outperform the market is more an act of luck than skill. To protect Model Wealth, Inc. clients from the higher costs of active management and the underperformance that can result, clients are advised to invest in passive strategies. The investment vehicles most commonly purchased for Model Wealth, Inc. clients are shares of registered, open-end mutual funds, exchange-traded funds, and individual equity and fixed income securities. Many of these investments can be purchased directly by clients without utilizing the services of an advisor. Mutual funds and exchange traded funds have embedded management fees and trading expenses. These fees and expenses are detailed in each fund’s prospectus. The following is a non-exclusive, non-static list of securities that Model Wealth, Inc. utilizes for its clients:  Equity Securities  Mutual Fund Securities  Exchange-traded funds  Corporate debt securities, commercial paper, and certificates of deposit  Municipal securities  U.S. Government Securities  Closed end funds  Direct Indexing Investing in securities involves a risk of loss that clients should be prepared to bear. Different types of investments carry varying degrees of risk, and an investor should not assume that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Model Wealth, Inc.) will be profitable or equal any specific performance levels. Without limitation, investors generally face the following risks: MODEL WEALTH, INC. ADV PART 2A Page 9 of 13 Interest Rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk may be caused by external factors independent of the fund’s specific investments as well as due to the fund’s specific investments. Additionally, each security’s price will fluctuate based on market movement and emotion, which may, or may not, be due to the security’s operations or changes in its true value. For example, political, economic, and social conditions may trigger market events which are temporarily negative, or temporarily positive. Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a decline in market value. Model Wealth, Inc. methods of analysis and investment strategies do not present any significant or unusual risks. However, every method of analysis has its own inherent risk. Item 9: Disciplinary Information Neither Model Wealth nor any of its associated persons have ever been convicted of, pled guilty or no contest to any felony or misdemeanor in a criminal or civil action in any foreign or domestic court. Neither Model Wealth nor any of its associated persons have ever been part of a proceeding before the SEC or any other industry regulatory agency or self-regulatory organization. Item 10: Other Financial Industry Activities and Affiliations Model Wealth serves its clients only as a registered investment advisor; it is not registered as a securities broker-dealer, or a futures commission merchant, commodity pool operator or commodity trading advisor. Model Wealth is not affiliated with a related person who is a broker- dealer, investment company, other investment advisor, financial planning firm, commodity pool operator, commodity trading adviser or futures commission merchant, banking or thrift institution, accounting firm, law firm, insurance company or agency, pension consultant, real estate broker or dealer, or an entity that creates or packages limited partnerships. MODEL WEALTH, INC. ADV PART 2A Page 10 of 13 Item 11: Code of Ethics, Participation, or Interest in Client Transactions and Personal Trading Code of Ethics Model Wealth strives to comply with applicable laws and regulations governing its practices; therefore, the Code of Ethics includes guidelines for professional standards of conduct for its Associated Persons. Model Wealth’s goal is to protect client’s interests at all times and to demonstrate a commitment to the fiduciary duties of honesty, good faith, and fair dealing with clients. All Associated Persons are expected to adhere strictly to these guidelines. Persons associated with Model Wealth are also required to report any violations of our Code of Ethics. Additionally, Model Wealth maintains and enforces written policies reasonably designed to prevent the misuse or dissemination of material, non-public information about clients or client account holdings by persons associated with Model Wealth. Model Wealth also abides by the Code of Ethics and Professional Responsibility adopted by the CFP Board of Standards, Inc. the principles of which include: Principle One – Act with honesty, integrity, competence, and diligence. Principle Two – Act in the client’s best interests. Principle Three – Exercise due care. Principle Four – Avoid or disclose and manage conflicts of interest. Principle Five – Maintain the confidentiality and protect the privacy of client information. Principle Six – Act in a manner that reflects positively on the financial planning profession. Clients or prospective clients may obtain a copy of our Code of Ethics by contacting Model Wealth at the telephone number on the cover page of this brochure. Participation or Interest in Client Transactions Model Wealth does not currently participate in securities in which it has a material financial interest. Model Wealth and its Associated Persons, as a matter of policy, do not recommend to clients, or buy or sell for client accounts, securities in which the firm or its Associated Persons has a material financial interest. Personal Trading Practices Model Wealth or its Associated Persons may buy or sell the same securities that they recommend to clients or securities in which clients are already invested. A conflict of interest may exist in such cases because Model Wealth Associated Persons have the ability to trade ahead of clients and potentially receive more favorable prices than they will receive. To eliminate this conflict of interest, it is Model Wealth’s policy that its Associated Persons shall not have priority over client accounts in the purchase or sale of securities. Item 12 - Brokerage Practices Model Wealth recommends the brokerage and custodial services of Charles Schwab & Co., Inc. (collectively referred to as “Schwab”) or Betterment Securities (collectively referred to as “Betterment”), both are registered broker-dealers and a member of the Financial Industry Regulatory Authority (FINRA) and the Securities Investor Protection Corporation (SIPC). Although Clients may request us to use a broker-dealer of their choosing, we generally recommend that Clients open brokerage accounts with Schwab or Betterment Securities. We believe that MODEL WEALTH, INC. ADV PART 2A Page 11 of 13 Schwab and Betterment provide quality execution services for clients at competitive prices. Price is not the sole factor Model Wealth considers in evaluating best execution. We also consider the quality of the brokerage services provided by Schwab and Betterment, including the value of research provided, the firm’s reputation, execution capabilities, commission rates, and responsiveness to our clients and our firm. In recognition of the value of research services and additional brokerage products and services Schwab and Betterment provide, clients may pay higher commissions and/or trading costs than those that may be available. Research and Other Soft Dollar Benefits As a registered investment adviser, Model Wealth will have access to the institutional platform of account custodians (Schwab and Betterment). As such, we will also have access to research products and technology services from your account custodian and/or other brokerage firm. These products may include financial publications, information about particular companies and industries, research software, rebalancing software, and other products or services that provide lawful and appropriate assistance to our firm in the performance of our investment decision-making and account maintenance responsibilities. Such products and services are provided to all investment advisers that utilize the institutional services platforms of these firms and are not considered to be paid for with soft dollars. However, you should be aware that the commissions charged by a broker for a particular transaction or set of transactions may be greater than the amounts another broker who did not provide services or products might charge. Block Trades In general, we do not combine multiple orders for shares of the same securities purchased for advisory accounts we manage (the practice of combining multiple orders for shares of the same securities is commonly referred to as “block trading”). Accordingly, you may pay different prices for the same securities transactions than other clients pay. Furthermore, we may not be able to buy and sell the same quantities of securities for you and you may pay higher commissions, fees, and/or transaction costs than other clients. Item 13 - Review of Accounts For clients who retain Model Wealth for ongoing, comprehensive services, Model Wealth conducts account reviews on an ongoing basis; however, all such clients bear the responsibility to advise Model Wealth of any changes in their investment objectives and/or financial situation. Model Wealth reviews client portfolios at least quarterly, and any of Model Wealth’s financial adviser may conduct those reviews. Reviews include an inspection of portfolio holdings, change in account values, and actual allocation of the account as compared to the recommended allocation. Model Wealth may conduct account reviews upon the occurrence of a triggering event, such as a change in client investment objectives and/or financial situation, market corrections, and by a client request. Model Wealth provides clients with written transaction confirmation notices and regular written summary account statements directly from the broker-dealer/custodian at least quarterly. Model Wealth may also provide a written periodic report summarizing account activity and performance. Item 14 - Client Referrals and Other Compensation Model Wealth does not receive any compensation for client referrals, nor does Model Wealth MODEL WEALTH, INC. ADV PART 2A Page 12 of 13 compensate third parties for client referrals received. Item 15 - Custody Model Wealth, Inc. does not take physical custody of clients’ assets or provide custodial services; however, because the Client’s independent custodian may directly debit their account(s) for the payment of advisory fees, Model Wealth is deemed to have constructive custody over client funds or securities. Client funds and securities are held by a bank, broker-dealer, or other independent, qualified custodian. Clients will receive account statements from the independent, qualified custodian(s) holding their funds and securities at least quarterly. The account statements from custodian(s) will indicate the amount of Model Wealth’s advisory fees deducted from their account(s) each billing period. Clients should carefully review account statements for accuracy. Model Wealth reports may vary from custodial statements based on account procedures, reporting dates, or valuation methodologies or certain securities. Model Wealth also aids with asset movements to simplify the management of client’s complex financial situations. As such, clients can issue to Model Wealth Standing Letters of Authority (SLOAs) that direct Model Wealth to move funds from and among client accounts from time to time and without obtaining written client consent for each movement of funds. Because of the authority and discretion invested in Model Wealth in the use of these SLOAs. Model Wealth is deemed to have constructive custody over client funds or securities. In the use of SLOAs, Model Wealth at all times adheres to the requirements set forth by the SEC to avoid the annual surprise audit otherwise required. Item 16 - Investment Discretion Model Wealth, Inc. accepts limited power of attorney to act on a discretionary basis for most of its clients to execute trades on their behalf; it results in Model Wealth’s authority to determine, without obtaining specific client consent, both the amount and type of securities to be bought or sold to satisfy client account objectives. Additionally, Model Wealth may accept any reasonable limitation or restriction to such authority on the account placed by the client. All limitations and restrictions placed on accounts must be present to Model Wealth in writing. If Model Wealth, Inc. has not been given discretionary authority, Model Wealth consults with the client prior to each trade. Item 17 - Voting Clients Securities Model Wealth, Inc. does not have authority to and does not vote proxies on behalf of clients. Clients retain the responsibility for receiving and voting proxies for securities maintained in their portfolios. Clients receive these proxies directly from either Custodian(s) or transfer agents. If requested, Model Wealth may provide advice to clients regarding proxy votes. If any conflict of interest exists, it will be disclosed to the client. Item 18 - Financial Information Registered investment advisors are required in this Item to provide you with certain financial information or disclosures about their financial condition. Because Model Wealth has no financial condition that impairs its ability to meet contractual and fiduciary commitments to clients, has not MODEL WEALTH, INC. ADV PART 2A Page 13 of 13 been the subject of a bankruptcy proceeding, and does not require prepayment of fees of $1,200 more than six months in advance and there is not required to provide a balance sheet to clients, Model Wealth is not required to provide such financial information. MODEL WEALTH, INC. ADV PART 2A Page 14 of 13