Overview

Assets Under Management: $467 million
Headquarters: NAPLES, FL
High-Net-Worth Clients: 85
Average Client Assets: $3 million

Services Offered

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

Fee Structure

Primary Fee Schedule (NAPLES WEALTH PLANNING, LLC - ADV 2A)

MinMaxMarginal Fee Rate
$0 and above 2.50%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $25,000 2.50%
$5 million $125,000 2.50%
$10 million $250,000 2.50%
$50 million $1,250,000 2.50%
$100 million $2,500,000 2.50%

Clients

Number of High-Net-Worth Clients: 85
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 75.41
Average High-Net-Worth Client Assets: $3 million
Total Client Accounts: 1,077
Discretionary Accounts: 529
Non-Discretionary Accounts: 548

Regulatory Filings

CRD Number: 330316
Last Filing Date: 2024-12-16 00:00:00
Website: https://napleswealthplanning.com

Form ADV Documents

Additional Brochure: NAPLES WEALTH PLANNING, LLC - ADV 2A (2025-10-24)

View Document Text
Naples Wealth Planning, LLC Form ADV Part 2A – Disclosure Brochure Effective: October 1, 2025 This Form ADV 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Naples Wealth Planning, LLC (“NWP” or the “Advisor”). If you have any questions about the contents of this Disclosure Brochure, please contact the Advisor at (239) 260-9386. NWP 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 through NWP to assist you in determining whether to retain the Advisor. Certain Advisory Persons of NWP provide advisory services under a practice name or “doing business as” name. However, advisory services are engaged exclusively through NWP. Additional information about NWP 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 by CRD# 330316. Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 www.napleswealthplanning.com Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement[s]”). 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 NWP. NWP believes that communication and transparency are the foundation of its relationship with Clients and will continually strive to provide its Clients with complete and accurate information at all times. NWP encourages all current and prospective Clients to read this Disclosure Brochure and discuss any questions you may have with us. And of course, we always welcome your feedback. Material Change This Disclosure Brochure has been amended and updated to reflect a change in NWP’s principal office and place of business as of October 1, 2025. The Advisor’s new address is 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103. The Firm’s telephone number and contact information have not changed. No other material changes have been made to this brochure since the last annual amendment filed on March 31, 2025. There have been no material changes to our business, services, fees, or disclosures—this amendment solely reflects the change of principal office. Future Changes From time to time, we may amend this Disclosure Brochure to reflect changes in our business practices, changes in regulations and routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to each Client annually and if a material change occurs in the business practices of NWP. 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 our firm name or our CRD #330316. You may also request a copy of this Disclosure Brochure at any time, by contacting the Advisor at (239) 260-9386. Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 2 Item 3 – Table of Contents Item 1 – Cover Page ................................................................................................................................................. 1 Item 2 – Material Changes ....................................................................................................................................... 2 Item 3 – Table of Contents ...................................................................................................................................... 3 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 ............................................................................................................................ 8 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 A. Methods of Analysis ...................................................................................................................................................... 9 B. Risk of Loss ................................................................................................................................................................. 10 Item 9 – Disciplinary Information .......................................................................................................................... 11 Item 10 – Other Financial Industry Activities and Affiliations ............................................................................ 12 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 ................................................................................................................... 13 Item 12 – Brokerage Practices .............................................................................................................................. 13 A. Recommendation of Custodian[s] ................................................................................................................................ 13 B. Aggregating and Allocating Trades .............................................................................................................................. 13 Item 13 – Review of Accounts .............................................................................................................................. 14 A. Frequency of Reviews ................................................................................................................................................. 14 B. Causes for Reviews .................................................................................................................................................... 14 C. Review Reports ............................................................................................................................................................ 14 Item 14 – Client Referrals and Other Compensation ........................................................................................... 14 A. Compensation Received by NWP ................................................................................................................................ 14 B. Compensation for Client Referrals ............................................................................................................................... 15 Item 15 – Custody .................................................................................................................................................. 15 Item 16 – Investment Discretion ........................................................................................................................... 15 Item 17 – Voting Client Securities ........................................................................................................................ 15 Item 18 – Financial Information ............................................................................................................................ 15 Privacy Policy ........................................................................................................................................................ 17 Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 3 Item 4 – Advisory Services A. Firm Information Naples Wealth Planning, LLC (“NWP” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). NWP which is organized as a Limited Liability Company (“LLC”) under the laws of the State of Florida. NWP was founded in July 2023. NWP is principally owned by MLA Capital Partners, LLC. The Principal Officers of NWP are Brian J. Bruneau and Richard J. Calhoun, Jr. Certain Advisory Persons market and deliver advisory services under a practice name or “doing business as”, whose name and logo may appear on marketing materials as approved by NWP, or client statements approved by the custodian. It is important to note that the businesses are legal entities of the Advisory Persons and not NWP, nor the custodian. However, advisory services are engaged exclusively through NWP. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by NWP. For information regarding this Disclosure Brochure, please contact Brian J. Bruneau (Chief Compliance Officer) at (239) 260-9386. B. Advisory Services Offered NWP provides investment advisory services to individuals, high net worth individuals, families, trusts, estates, businesses, charitable organizations, and institutions (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under 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. Our fiduciary commitment is further described in our Code of Ethics. For more information regarding our Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services NWP 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. NWP works with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create an investment strategy. NWP will then design an investment strategy that may include the Advisor’s internal investment management and/or the use of independent managers and/or internal investment management. Internal Management – NWP will construct Client portfolios utilizing mutual funds, exchange-traded funds (“ETFs”), mutual funds, individual equities, and individual bonds. The Advisor may also utilize options, private investments, and other types of investments, as appropriate, to meet the needs of certain Clients. NWP’s investment strategies are primarily long-term focused, but the Advisor may buy, sell, or re-allocate investments that have been held for less than one year to meet the objectives of the Client or due to market conditions. NWP 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. NWP evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. NWP may recommend, on occasion, redistributing investment allocations to diversify the portfolio. NWP 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. NWP 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 Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 4 At no time will NWP accept or maintain custody of a Client’s funds or securities, except for the limited authority as detailed in Item 15 - Custody. All Client assets will be managed within their designated brokerage account or pension account, pursuant to the Client investment advisory agreement. Use of Independent Managers – NWP may recommend that a Client utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) in connection with a Client’s investment strategy[ies]. In such instances, the Client may be required to authorize and enter into an advisory agreement with the Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide investment management and related services. The Advisor will assist in the development of investment policy recommendations and managing the ongoing Client relationship. The Advisor will perform initial and ongoing oversight and due diligence over the selected Independent Manager[s] to ensure the Independent Managers’ strategies and target allocations remain aligned with the Clients’ investment objectives and overall best interests. The Client, prior to entering into an agreement with unaffiliated investment manager[s] or investment platform[s], will be provided with the Independent Manager's Form ADV 2A (or a brochure that makes the appropriate disclosures). Participant Account Management: As part of the Advisor’s Investment Management Services, when appropriate, the Advisor will use a third-party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Adviser will review the current account allocations. When deemed necessary, Adviser will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Financial Planning Services NWP will typically provide a variety of financial planning services to Clients. Services may be provided as part of an overall wealth management engagement or under separate agreement, pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals, objectives, and financial situation. Generally, such financial planning services will involve preparing a financial plan or rendering a 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, estate planning, personal savings, education savings and 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. NWP may also refer Clients to an accountant, attorney, or other specialist, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of Client’s financial situation, observations, and Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 5 recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. NWP also provides ongoing consulting services to clients. These engagements are ongoing until either the Advisor or Client terminates their executed agreement. Financial planning and consulting recommendations may pose a potential conflict between the interests of the Advisor and the interests of the Client. For example, a recommendation to engage the Advisor for investment management services or to increase the level of investment assets with the Advisor would pose a conflict, as it would increase the advisory fees paid to the Advisor. 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 effect the transaction through the Advisor. C. Client Account Management Prior to engaging NWP to provide investment advisory services, each Client is required to enter into one or more advisory 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 – NWP, in connection with the Client, will develop an investment strategy targeted to achieve the Client’s investment goals and objectives. • Asset Allocation – NWP 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 – NWP will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – NWP will provide investment management and ongoing oversight of the Client’s portfolio. D. Wrap Fee Programs NWP does not manage a wrap fee program. E. Assets Under Management As of December 31, 2024, NWP manages $356,289,605 in Client assets, which are managed on a discretionary and non- discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client shall sign one or more agreements that detail the responsibilities of NWP and the Client. A. Fees for Advisory Services Investment Management Services Investment management fees are paid monthly, in advance of each calendar month, pursuant to the terms of the investment management agreement. Investment management fees are based on the market value of assets under management at the end of the prior month. Wealth management fees range from 0.50% to 2.50% annually. based on several factors, including, but not limited to the services offered to the Client, the complexity of the services to be provided, the level of Client assets managed by the Advisor, and/or the overall relationship with the Advisor. The investment management fee in the first month of service is prorated from the inception date of the account[s] to the end of the first month. Fees may be negotiable at the sole discretion of the Advisor. Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 6 The fees above may include financial planning services at the sole discretion of the Advisor. The investment advisory fee in the first month of service is prorated from the inception date of the account[s] to the end of the first month. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with Advisor. All securities held in accounts managed by NWP will be independently valued by the designated Custodian. NWP will not have the authority or responsibility to value portfolio securities. The Advisor typically offers a tiered, incremental fee schedule (as detailed above) where the rate is reduced as assets under management increase. In certain circumstances, the Advisor may charge a fixed annual rate or fixed fee for its services. The Client’s fees will take into consideration the aggregate assets under management with the Advisor across all accounts, unless otherwise agreed in writing. All securities held in accounts managed by NWP will be independently valued by the Custodian. NWP 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 NWP’s right to terminate an account. Additions may be in cash or securities provided that NWP 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 NWP, subject to the usual and customary securities settlement procedures. However, NWP designs its portfolios as long-term investments, and the withdrawal of assets may impair the achievement of a Client’s investment objectives. NWP may consult with its Clients about the options and ramifications of transferring securities. However, Clients are advised that when transferred securities are liquidated, they are subject to transaction fees, fees assessed at the mutual fund level (i.e. contingent deferred sales charge) and/or tax ramifications. Use of Independent Managers For Client account[s] implemented through an Independent Manager, the Client’s overall fees may include NWP’s investment advisory fee (as noted above) plus advisory fees and/or platform fees charged by the Independent Manager[s], as applicable. The Independent Manager may assume responsibility for calculating the Client’s fees and deduct all fees from the Client’s account[s]. In such instances, NWP will not charge its fee separately on those assets. Financial Planning Services NWP may include financial planning services in an overall wealth management engagement or contract for these services separately. The Advisor may also offer its services as a separate fixed project fee engagement ranging from $1,000 to $10,000. The Advisor’s fee is based on the complexity of the services to be provided and the experience level of the Advisory Person providing the services. An estimate for total costs will be provided to the Client prior to engaging for these services. NWP provides ongoing consulting services as a stand-alone service. The fees associated with ongoing consulting range from $10,000 - $200,000. This fee is based on the complexity of the services to be provided and the experience level of the Advisory Person providing this service. An estimate for total costs will be provided to the Client prior to engaging for these services. Fees for financial planning services may be negotiable at the sole discretion of the Advisor. B. Fee Billing Investment Management Services Investment advisory fees will be 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 respective month-end date. The amount due is calculated by applying the average daily rate to the total assets under management with NWP at the end of the prior month. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. It is the responsibility of the Client to verify the accuracy of these fees as listed on the custodian’s brokerage statement as the Custodian does not assume this responsibility. Clients provide written authorization permitting NWP to be paid Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 7 directly from their accounts held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. Use of Independent Managers Client account[s] implemented through Independent Manager[s] will be billed in accordance to the separate agreement[s] with the respective parties. These parties will typically add NWP’s investment advisory fee and deduct the overall fee from the Client’s account[s]. Financial Planning Services Financial planning engagements may require an advance payment of fees up to 50% of the expected total cost of the engagement. Upon completion of the engagement deliverable[s], the remaining balance of the engagement fees shall be invoiced by the Advisor and are due upon receipt of the invoice. Ongoing consulting services are charged monthly in advance. The Advisor does not collect advance fees of $1,200 or more for any services that will be completed six (6) months or more in the future. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than NWP, 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, if applicable. The Advisor’s recommended Custodian typically provides trading in ETFs and equity securities without cost to the Client. Securities transaction fees are typically charged by the Custodian for mutual funds and other types of investments. The fees charged by NWP are separate and distinct from these custody and execution fees. In addition, all fees paid to NWP 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 could invest in these products directly, without the services of NWP, but would not receive the services provided by NWP 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 NWP to fully understand the total fees to be paid. D. Advance Payment of Fees and Termination Investment Management Services NWP is compensated for its investment advisory services in advance of the month in which services are rendered. Either party may request to terminate the investment advisory agreement with NWP, at any time, by providing advance written notice to the other party. The Client shall be responsible for investment advisory fees up to and including the effective date of termination. Upon termination, the Advisor will promptly refund any unearned, prepaid advisory fees. The Client’s investment advisory agreement with the Advisor is non-transferable without the Client’s prior consent. Use of Independent Managers In the event that a Client should wish to terminate their relationship with an Independent Manager, the terms for termination will be set forth in the respective agreements between the Client and those third parties. NWP will assist the Client with the termination and transition as appropriate. Financial Planning Services NWP may be partially compensated for its financial planning services in advance of providing services. 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, Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 8 the Client shall be responsible for planning fees based on the percentage of the engagement deliverables completed. Upon termination, the Advisor will refund any unearned, prepaid fees. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent. E. Compensation for Sales of Securities NWP does not buy or sell securities to earn securities transaction fees and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. Certain Advisory Persons are also a Registered Representative of American Global Wealth Management, Inc., (“AGWM”), a registered broker-dealer (CRD# 7388), member FINRA, SIPC. In an Advisory Person’s separate capacity as a Registered Representative, the Advisory Person may implement securities transactions through AGWM and not through NWP. In such instances, the Advisory Person will receive commission-based compensation in connection with the purchase and sale of securities, including 12b-1 fees for the sale of investment company products. Compensation earned by the Advisory Person in his or her capacity as a Registered Representative is separate and in addition to the Advisor’s fees as noted in 5.A. above. This relationship presents a conflict of interest as an Advisory Person who is a Registered Representative may an incentive to effect securities transactions for the purpose of generating commissions rather than solely based on needs of the Client. Clients are not obligated to implement any recommendation provided by the Advisor nor its Advisory Persons. Neither the Advisor nor its Advisory Persons will earn ongoing investment advisory fees in connection with any products or services implemented in the Advisory Person’s separate capacity as a Registered Representative. Please see Item below. Certain Advisory Persons are also licensed as independent insurance professionals. As an independent insurance professional, an Advisory Person will earn commission-based compensation for selling insurance products, including insurance products they sell to Clients. Insurance commissions earned by an Advisory Person are separate and in addition to advisory fees. This practice presents a conflict of interest because a person providing investment advice on behalf of the Advisor who is also an insurance agent has an incentive to recommend insurance products to Clients for the purpose of generating commissions rather than solely based on Client needs. However, Clients are under no obligation, contractually or otherwise, to purchase insurance products through any person affiliated with the Advisor. Please see Item 10 – Other Financial Industry Activities and Affiliations. Item 6 – Performance-Based Fees and Side-By-Side Management NWP does not charge performance-based fees for its investment advisory services. The fees charged by NWP are as described in “Item 5 – Fees and Compensation” above and are not based upon the capital appreciation of the funds or securities held by any Client. NWP 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 NWP provides investment advisory services to individuals, high net worth individuals, families, trusts, estates, businesses, charitable organizations, and institutions. NWP requires a minimum relationship size of $250,000, which may be reduced at its sole discretion. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis NWP primarily employs fundamental and technical analysis methods in developing investment strategies for its Clients. Research and analysis from NWP 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. Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 9 Fundamental analysis utilizes economic and business indicators as investment selection criteria. These criteria are generally 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 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 NWP will be able to accurately predict such a reoccurrence. As noted above, NWP generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. NWP 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, NWP 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. NWP 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. 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 a Client’s account[s]. 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 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. Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 10 Bond ETFs – 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 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. Fixed Income Risk - The prices of fixed income securities (bonds) respond to economic developments, particularly interest rate changes, as well as to perceptions about the creditworthiness of individual issuers. Fixed income securities will decrease in value if interest rates rise and vice versa, and the volatility of lower-rated securities is even greater than that of higher-rated securities. Also, longer-term securities are more volatile, so the average maturity or duration of these securities affects risk. Floating rate securities may decline in value if market interest rates or interest rates paid by them do not move as expected. Conversely, floating rate securities will not generally rise in value if market interest rates decline. Floating rate securities may be subject to greater liquidity risk than other debt securities, meaning that there may be limitations on the Fund’s ability to sell the securities at any given time. Other risk factors include credit risk (the debtor may default), extension risk (an issuer may exercise its right to repay principal on a fixed rate obligation held by the Fund later than expected), and prepayment risk (the debtor may pay its obligation early, reducing the amount of interest payments). These risks could affect the value of a particular investment by the Fund, possibly causing the Fund's share price and total return to be reduced and fluctuate more than other types of investments. The lower the rating of a debt security, the greater its risks. In addition, these risks are often magnified for securities rated below investment grade, often referred to as “junk bonds,” and adverse changes in economic conditions or market perception are likely to cause issuers of these securities to be unable to meet their obligations to repay principal and interest to investors. Options Contracts – 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 Borrowings – 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 Investments (Limited Partnerships) – 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. 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. 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. Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 11 Item 9 – Disciplinary Information There are no legal, regulatory, or disciplinary events involving Naples Wealth Planning, LLC, or its management persons. We value the trust you place in us. As we advise all Clients, we encourage you to perform the requisite due diligence on any advisor or service provider with whom you partner. Our backgrounds are on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with our firm name or our CRD# 330316. Item 10 – Other Financial Industry Activities and Affiliations Broker-Dealer Affiliation As noted in Item 5, certain Advisory Persons are also Registered Representatives of AGWM. In an Advisory Person’s separate capacity as a Registered Representative, the Advisory Person will receive commissions for the implementation of recommendations for commissionable transactions. Clients are not obligated to implement any recommendation provided by an Advisory Person. Neither the Advisor nor its Advisory Persons will earn ongoing investment advisory fees in connection with any services implemented in an Advisory Person’s separate capacity as a Registered Representative. Insurance Agency Affiliations As noted in Item 5, certain Advisory Persons are also licensed insurance professionals. Implementation of insurance recommendations is separate and apart from an Advisory Person's role with the Advisor. As an insurance professional, an Advisory Person will receive customary commissions and other related revenues from the various insurance companies whose products are sold. An Advisory Person is not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents 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 Person or the Advisor. Use of Independent Managers As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment portfolio with one or more Independent Managers. The Advisor does not receive any compensation, nor does this present a material conflict of interest. The Advisor will only earn its wealth management fee as described in Item 5.A. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics NWP has implemented a Code of Ethics that defines our fiduciary commitment to each Client. This Code of Ethics applies to all persons associated with NWP (our “Supervised Persons”). The Code of Ethics was developed to provide general ethical guidelines and specific instructions regarding our duties to you, our Client. NWP and its personnel owe a duty of loyalty, fairness, and good faith towards each Client. It is the obligation of NWP 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 of Ethics covers a range of topics that address employee ethics and conflicts of interest. To request a copy of our Code of Ethics, please contact us at (239) 260-9386. B. Personal Trading with Material Interest NWP allows the purchase or sale of the same securities that may be recommended to and purchased on behalf of Clients. NWP 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. NWP does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients NWP allows the purchase or sale of the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities we recommend (purchase or sell) to you presents a potential conflict of interest that, as fiduciaries, we must disclose to you and mitigate through policies and procedures. As noted above, we have adopted a Code of Ethics, which addresses insider trading (material non-public information controls) and personal securities reporting procedures. When trading for personal accounts, Supervised Persons of NWP may Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 12 have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can potentially 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 NWP requiring reporting of personal securities trades by its employees for review by the Chief Compliance Officer (“CCO”). We have also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While NWP allows the purchase or sale of the same securities that may be recommended and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no time will NWP transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] NWP does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer or custodian (herein the "Custodian") to safeguard Client assets and authorize NWP to direct trades to this Custodian as agreed in the investment advisory agreement. Further, NWP does not have the discretionary authority to negotiate commissions on behalf of our Clients on a trade-by- trade basis. Where NWP does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients. NWP 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, and its overall reputation. Clients are not obligated to use the recommended Custodian and will not incur any extra fee or cost associated with using a Custodian not recommended by NWP. However, if the recommended Custodian is not engaged, NWP may be limited in the services it can provide comparable to other Clients. Further, as certain Advisory Persons are also Registered Representatives of AGWM, the Advisor may be limited in using other broker-dealers/custodians as AGWM must approve the use of any outside broker-dealer/custodian. NWP will recommend that Clients establish their account[s] at Charles Schwab & Co., Inc. (“Schwab”), a FINRA- registered broker-dealer and member SIPC. Schwab will serve as the Client’s “qualified custodian”. NWP 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 whereby an advisor enters into an agreement to place security trades with the broker in exchange for research and other services. NWP does not participate in soft dollar programs sponsored or offered by any broker-dealer. However, the Advisor does receive certain economic benefits from Charles Schwab. Please see Item 14 below. 2. Brokerage Referrals - NWP - does not receive any compensation from any third party in connection with the recommendation for establishing a brokerage account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where NWP will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective brokerage 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]). In selecting the Custodian, NWP 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 designated 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 Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 13 most favorable net results considering such factors as 1) price, 2) size of order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the broker. NWP will execute its transactions through an unaffiliated broker- dealer selected by the Client. NWP may aggregate orders in a block trade or trades when securities are purchased or sold through the same broker-dealer for multiple (discretionary) accounts. 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 particular Client accounts. Item 13 – Review of Accounts A. Frequency of Reviews Investments in Client accounts are monitored on a regular and continuous basis by Partners of NWP and periodically by the CCO. Formal reviews are generally conducted at least annually or more or less 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 or less 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 NWP 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 periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by NWP Participation in Institutional Advisor Platform: Charles Schwab NWP has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like NWP. As a registered investment advisor participating on the Schwab Advisor Services platform, NWP 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 potential 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. We receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab. In addition, Schwab has also agreed to pay for certain products and services for which we would otherwise have to pay once the value of our clients’ assets in accounts at Schwab reaches a certain size. [In some cases, a recipient of such payments is an affiliate of ours or another party which has some pecuniary, financial, or other interests in us (or in which we have such an interest).] You do not pay more for assets maintained at Schwab as a result of these arrangements. However, we benefit from the arrangement because the cost of these services would otherwise be borne directly by us. You should consider these conflicts of interest when selecting a custodian. The products and services provided by Schwab, how they benefit us, and the related conflicts of interest are described below. NWP also receives for a limited time financial assistance whereby Schwab reimburses the Advisor for certain expenditures including software and Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 14 compliance 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 NWP 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 potential conflict of interest. NWP believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. B. Compensation for Client Referrals Certain Clients may be referred to the Advisor by either an affiliated or unaffiliated party (herein "Promoter") and receive, directly or indirectly, compensation for the Client referral. In such instances, the Advisor will compensate the Promoter with a fee in accordance with Rule 206(4)-1 of the Advisers Act and any corresponding state securities requirements. Any such compensation shall be paid solely from the investment advisory fees earned by the Advisor and shall not result in any additional charge to the Client. Item 15 – Custody NWP does not accept or maintain custody of any Client accounts, except for the authorized deduction of the advisor’s fee. 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 NWP to utilize that Custodian for the Client’s security transactions. NWP encourages Clients to review statements provided by the account Custodian. 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 also have custody of those assets. In order to avoid additional regulatory requirements, the Advisor has adopted safeguards to ensure that the money movements are completed in accordance with the Client’s instructions. Item 16 – Investment Discretion NWP 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 NWP. 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 an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by NWP will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities NWP 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. Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 15 Item 18 – Financial Information Neither NWP, nor its management, have any adverse financial situations that would reasonably impair the ability of NWP to meet all obligations to its Clients. Neither NWP, nor any of its Advisory Persons, has been subject to a bankruptcy or financial compromise. NWP is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect fees of $1,200 or more for services to be performed six months or more in advance. Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 16 Privacy Policy Effective Date: March 11, 2024 Our Commitment to You Naples Wealth Planning, LLC (“NWP” 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. NWP (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. NWP 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? 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 Account applications and forms Investment questionnaires and suitability documents Transactional information with us or others 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. Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 17 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 NWP Wealth shares Client information with American Global Wealth Management, Inc. (“AGWM”). This sharing is due to the oversight AGWM has over certain Supervised Persons of the Advisor. You may also contact us at any time for a copy of the AGWM Privacy Policy. Marketing Purposes NWP 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 NWP 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]. No Not Shared Information About Former Clients NWP 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 Privacy 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 the Advisor at (239) 260-9386. Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 18

Additional Brochure: NWP FORM ADV 2A - (AMENDED OCTOBER 2025) (2025-10-24)

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Naples Wealth Planning, LLC Form ADV Part 2A – Disclosure Brochure Effective: October 1, 2025 This Form ADV 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Naples Wealth Planning, LLC (“NWP” or the “Advisor”). If you have any questions about the contents of this Disclosure Brochure, please contact the Advisor at (239) 260-9386. NWP 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 through NWP to assist you in determining whether to retain the Advisor. Certain Advisory Persons of NWP provide advisory services under a practice name or “doing business as” name. However, advisory services are engaged exclusively through NWP. Additional information about NWP 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 by CRD# 330316. Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 www.napleswealthplanning.com Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement[s]”). 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 NWP. NWP believes that communication and transparency are the foundation of its relationship with Clients and will continually strive to provide its Clients with complete and accurate information at all times. NWP encourages all current and prospective Clients to read this Disclosure Brochure and discuss any questions you may have with us. And of course, we always welcome your feedback. Material Change This Disclosure Brochure has been amended and updated to reflect a change in NWP’s principal office and place of business as of October 1, 2025. The Advisor’s new address is 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103. The Firm’s telephone number and contact information have not changed. No other material changes have been made to this brochure since the last annual amendment filed on March 31, 2025. There have been no material changes to our business, services, fees, or disclosures—this amendment solely reflects the change of principal office. Future Changes From time to time, we may amend this Disclosure Brochure to reflect changes in our business practices, changes in regulations and routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to each Client annually and if a material change occurs in the business practices of NWP. 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 our firm name or our CRD #330316. You may also request a copy of this Disclosure Brochure at any time, by contacting the Advisor at (239) 260-9386. Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 2 Item 3 – Table of Contents Item 1 – Cover Page ................................................................................................................................................. 1 Item 2 – Material Changes ....................................................................................................................................... 2 Item 3 – Table of Contents ...................................................................................................................................... 3 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 ............................................................................................................................ 8 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 A. Methods of Analysis ...................................................................................................................................................... 9 B. Risk of Loss ................................................................................................................................................................. 10 Item 9 – Disciplinary Information .......................................................................................................................... 11 Item 10 – Other Financial Industry Activities and Affiliations ............................................................................ 12 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 ................................................................................................................... 13 Item 12 – Brokerage Practices .............................................................................................................................. 13 A. Recommendation of Custodian[s] ................................................................................................................................ 13 B. Aggregating and Allocating Trades .............................................................................................................................. 13 Item 13 – Review of Accounts .............................................................................................................................. 14 A. Frequency of Reviews ................................................................................................................................................. 14 B. Causes for Reviews .................................................................................................................................................... 14 C. Review Reports ............................................................................................................................................................ 14 Item 14 – Client Referrals and Other Compensation ........................................................................................... 14 A. Compensation Received by NWP ................................................................................................................................ 14 B. Compensation for Client Referrals ............................................................................................................................... 15 Item 15 – Custody .................................................................................................................................................. 15 Item 16 – Investment Discretion ........................................................................................................................... 15 Item 17 – Voting Client Securities ........................................................................................................................ 15 Item 18 – Financial Information ............................................................................................................................ 15 Privacy Policy ........................................................................................................................................................ 17 Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 3 Item 4 – Advisory Services A. Firm Information Naples Wealth Planning, LLC (“NWP” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). NWP which is organized as a Limited Liability Company (“LLC”) under the laws of the State of Florida. NWP was founded in July 2023. NWP is principally owned by MLA Capital Partners, LLC. The Principal Officers of NWP are Brian J. Bruneau and Richard J. Calhoun, Jr. Certain Advisory Persons market and deliver advisory services under a practice name or “doing business as”, whose name and logo may appear on marketing materials as approved by NWP, or client statements approved by the custodian. It is important to note that the businesses are legal entities of the Advisory Persons and not NWP, nor the custodian. However, advisory services are engaged exclusively through NWP. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by NWP. For information regarding this Disclosure Brochure, please contact Brian J. Bruneau (Chief Compliance Officer) at (239) 260-9386. B. Advisory Services Offered NWP provides investment advisory services to individuals, high net worth individuals, families, trusts, estates, businesses, charitable organizations, and institutions (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under 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. Our fiduciary commitment is further described in our Code of Ethics. For more information regarding our Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services NWP 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. NWP works with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create an investment strategy. NWP will then design an investment strategy that may include the Advisor’s internal investment management and/or the use of independent managers and/or internal investment management. Internal Management – NWP will construct Client portfolios utilizing mutual funds, exchange-traded funds (“ETFs”), mutual funds, individual equities, and individual bonds. The Advisor may also utilize options, private investments, and other types of investments, as appropriate, to meet the needs of certain Clients. NWP’s investment strategies are primarily long-term focused, but the Advisor may buy, sell, or re-allocate investments that have been held for less than one year to meet the objectives of the Client or due to market conditions. NWP 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. NWP evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. NWP may recommend, on occasion, redistributing investment allocations to diversify the portfolio. NWP 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. NWP 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 Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 4 At no time will NWP accept or maintain custody of a Client’s funds or securities, except for the limited authority as detailed in Item 15 - Custody. All Client assets will be managed within their designated brokerage account or pension account, pursuant to the Client investment advisory agreement. Use of Independent Managers – NWP may recommend that a Client utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) in connection with a Client’s investment strategy[ies]. In such instances, the Client may be required to authorize and enter into an advisory agreement with the Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide investment management and related services. The Advisor will assist in the development of investment policy recommendations and managing the ongoing Client relationship. The Advisor will perform initial and ongoing oversight and due diligence over the selected Independent Manager[s] to ensure the Independent Managers’ strategies and target allocations remain aligned with the Clients’ investment objectives and overall best interests. The Client, prior to entering into an agreement with unaffiliated investment manager[s] or investment platform[s], will be provided with the Independent Manager's Form ADV 2A (or a brochure that makes the appropriate disclosures). Participant Account Management: As part of the Advisor’s Investment Management Services, when appropriate, the Advisor will use a third-party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Adviser will review the current account allocations. When deemed necessary, Adviser will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Financial Planning Services NWP will typically provide a variety of financial planning services to Clients. Services may be provided as part of an overall wealth management engagement or under separate agreement, pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals, objectives, and financial situation. Generally, such financial planning services will involve preparing a financial plan or rendering a 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, estate planning, personal savings, education savings and 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. NWP may also refer Clients to an accountant, attorney, or other specialist, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of Client’s financial situation, observations, and Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 5 recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. NWP also provides ongoing consulting services to clients. These engagements are ongoing until either the Advisor or Client terminates their executed agreement. Financial planning and consulting recommendations may pose a potential conflict between the interests of the Advisor and the interests of the Client. For example, a recommendation to engage the Advisor for investment management services or to increase the level of investment assets with the Advisor would pose a conflict, as it would increase the advisory fees paid to the Advisor. 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 effect the transaction through the Advisor. C. Client Account Management Prior to engaging NWP to provide investment advisory services, each Client is required to enter into one or more advisory 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 – NWP, in connection with the Client, will develop an investment strategy targeted to achieve the Client’s investment goals and objectives. • Asset Allocation – NWP 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 – NWP will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – NWP will provide investment management and ongoing oversight of the Client’s portfolio. D. Wrap Fee Programs NWP does not manage a wrap fee program. E. Assets Under Management As of December 31, 2024, NWP manages $356,289,605 in Client assets, which are managed on a discretionary and non- discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client shall sign one or more agreements that detail the responsibilities of NWP and the Client. A. Fees for Advisory Services Investment Management Services Investment management fees are paid monthly, in advance of each calendar month, pursuant to the terms of the investment management agreement. Investment management fees are based on the market value of assets under management at the end of the prior month. Wealth management fees range from 0.50% to 2.50% annually. based on several factors, including, but not limited to the services offered to the Client, the complexity of the services to be provided, the level of Client assets managed by the Advisor, and/or the overall relationship with the Advisor. The investment management fee in the first month of service is prorated from the inception date of the account[s] to the end of the first month. Fees may be negotiable at the sole discretion of the Advisor. Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 6 The fees above may include financial planning services at the sole discretion of the Advisor. The investment advisory fee in the first month of service is prorated from the inception date of the account[s] to the end of the first month. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with Advisor. All securities held in accounts managed by NWP will be independently valued by the designated Custodian. NWP will not have the authority or responsibility to value portfolio securities. The Advisor typically offers a tiered, incremental fee schedule (as detailed above) where the rate is reduced as assets under management increase. In certain circumstances, the Advisor may charge a fixed annual rate or fixed fee for its services. The Client’s fees will take into consideration the aggregate assets under management with the Advisor across all accounts, unless otherwise agreed in writing. All securities held in accounts managed by NWP will be independently valued by the Custodian. NWP 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 NWP’s right to terminate an account. Additions may be in cash or securities provided that NWP 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 NWP, subject to the usual and customary securities settlement procedures. However, NWP designs its portfolios as long-term investments, and the withdrawal of assets may impair the achievement of a Client’s investment objectives. NWP may consult with its Clients about the options and ramifications of transferring securities. However, Clients are advised that when transferred securities are liquidated, they are subject to transaction fees, fees assessed at the mutual fund level (i.e. contingent deferred sales charge) and/or tax ramifications. Use of Independent Managers For Client account[s] implemented through an Independent Manager, the Client’s overall fees may include NWP’s investment advisory fee (as noted above) plus advisory fees and/or platform fees charged by the Independent Manager[s], as applicable. The Independent Manager may assume responsibility for calculating the Client’s fees and deduct all fees from the Client’s account[s]. In such instances, NWP will not charge its fee separately on those assets. Financial Planning Services NWP may include financial planning services in an overall wealth management engagement or contract for these services separately. The Advisor may also offer its services as a separate fixed project fee engagement ranging from $1,000 to $10,000. The Advisor’s fee is based on the complexity of the services to be provided and the experience level of the Advisory Person providing the services. An estimate for total costs will be provided to the Client prior to engaging for these services. NWP provides ongoing consulting services as a stand-alone service. The fees associated with ongoing consulting range from $10,000 - $200,000. This fee is based on the complexity of the services to be provided and the experience level of the Advisory Person providing this service. An estimate for total costs will be provided to the Client prior to engaging for these services. Fees for financial planning services may be negotiable at the sole discretion of the Advisor. B. Fee Billing Investment Management Services Investment advisory fees will be 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 respective month-end date. The amount due is calculated by applying the average daily rate to the total assets under management with NWP at the end of the prior month. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. It is the responsibility of the Client to verify the accuracy of these fees as listed on the custodian’s brokerage statement as the Custodian does not assume this responsibility. Clients provide written authorization permitting NWP to be paid Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 7 directly from their accounts held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. Use of Independent Managers Client account[s] implemented through Independent Manager[s] will be billed in accordance to the separate agreement[s] with the respective parties. These parties will typically add NWP’s investment advisory fee and deduct the overall fee from the Client’s account[s]. Financial Planning Services Financial planning engagements may require an advance payment of fees up to 50% of the expected total cost of the engagement. Upon completion of the engagement deliverable[s], the remaining balance of the engagement fees shall be invoiced by the Advisor and are due upon receipt of the invoice. Ongoing consulting services are charged monthly in advance. The Advisor does not collect advance fees of $1,200 or more for any services that will be completed six (6) months or more in the future. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than NWP, 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, if applicable. The Advisor’s recommended Custodian typically provides trading in ETFs and equity securities without cost to the Client. Securities transaction fees are typically charged by the Custodian for mutual funds and other types of investments. The fees charged by NWP are separate and distinct from these custody and execution fees. In addition, all fees paid to NWP 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 could invest in these products directly, without the services of NWP, but would not receive the services provided by NWP 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 NWP to fully understand the total fees to be paid. D. Advance Payment of Fees and Termination Investment Management Services NWP is compensated for its investment advisory services in advance of the month in which services are rendered. Either party may request to terminate the investment advisory agreement with NWP, at any time, by providing advance written notice to the other party. The Client shall be responsible for investment advisory fees up to and including the effective date of termination. Upon termination, the Advisor will promptly refund any unearned, prepaid advisory fees. The Client’s investment advisory agreement with the Advisor is non-transferable without the Client’s prior consent. Use of Independent Managers In the event that a Client should wish to terminate their relationship with an Independent Manager, the terms for termination will be set forth in the respective agreements between the Client and those third parties. NWP will assist the Client with the termination and transition as appropriate. Financial Planning Services NWP may be partially compensated for its financial planning services in advance of providing services. 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, Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 8 the Client shall be responsible for planning fees based on the percentage of the engagement deliverables completed. Upon termination, the Advisor will refund any unearned, prepaid fees. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent. E. Compensation for Sales of Securities NWP does not buy or sell securities to earn securities transaction fees and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. Certain Advisory Persons are also a Registered Representative of American Global Wealth Management, Inc., (“AGWM”), a registered broker-dealer (CRD# 7388), member FINRA, SIPC. In an Advisory Person’s separate capacity as a Registered Representative, the Advisory Person may implement securities transactions through AGWM and not through NWP. In such instances, the Advisory Person will receive commission-based compensation in connection with the purchase and sale of securities, including 12b-1 fees for the sale of investment company products. Compensation earned by the Advisory Person in his or her capacity as a Registered Representative is separate and in addition to the Advisor’s fees as noted in 5.A. above. This relationship presents a conflict of interest as an Advisory Person who is a Registered Representative may an incentive to effect securities transactions for the purpose of generating commissions rather than solely based on needs of the Client. Clients are not obligated to implement any recommendation provided by the Advisor nor its Advisory Persons. Neither the Advisor nor its Advisory Persons will earn ongoing investment advisory fees in connection with any products or services implemented in the Advisory Person’s separate capacity as a Registered Representative. Please see Item below. Certain Advisory Persons are also licensed as independent insurance professionals. As an independent insurance professional, an Advisory Person will earn commission-based compensation for selling insurance products, including insurance products they sell to Clients. Insurance commissions earned by an Advisory Person are separate and in addition to advisory fees. This practice presents a conflict of interest because a person providing investment advice on behalf of the Advisor who is also an insurance agent has an incentive to recommend insurance products to Clients for the purpose of generating commissions rather than solely based on Client needs. However, Clients are under no obligation, contractually or otherwise, to purchase insurance products through any person affiliated with the Advisor. Please see Item 10 – Other Financial Industry Activities and Affiliations. Item 6 – Performance-Based Fees and Side-By-Side Management NWP does not charge performance-based fees for its investment advisory services. The fees charged by NWP are as described in “Item 5 – Fees and Compensation” above and are not based upon the capital appreciation of the funds or securities held by any Client. NWP 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 NWP provides investment advisory services to individuals, high net worth individuals, families, trusts, estates, businesses, charitable organizations, and institutions. NWP requires a minimum relationship size of $250,000, which may be reduced at its sole discretion. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis NWP primarily employs fundamental and technical analysis methods in developing investment strategies for its Clients. Research and analysis from NWP 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. Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 9 Fundamental analysis utilizes economic and business indicators as investment selection criteria. These criteria are generally 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 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 NWP will be able to accurately predict such a reoccurrence. As noted above, NWP generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. NWP 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, NWP 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. NWP 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. 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 a Client’s account[s]. 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 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. Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 10 Bond ETFs – 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 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. Fixed Income Risk - The prices of fixed income securities (bonds) respond to economic developments, particularly interest rate changes, as well as to perceptions about the creditworthiness of individual issuers. Fixed income securities will decrease in value if interest rates rise and vice versa, and the volatility of lower-rated securities is even greater than that of higher-rated securities. Also, longer-term securities are more volatile, so the average maturity or duration of these securities affects risk. Floating rate securities may decline in value if market interest rates or interest rates paid by them do not move as expected. Conversely, floating rate securities will not generally rise in value if market interest rates decline. Floating rate securities may be subject to greater liquidity risk than other debt securities, meaning that there may be limitations on the Fund’s ability to sell the securities at any given time. Other risk factors include credit risk (the debtor may default), extension risk (an issuer may exercise its right to repay principal on a fixed rate obligation held by the Fund later than expected), and prepayment risk (the debtor may pay its obligation early, reducing the amount of interest payments). These risks could affect the value of a particular investment by the Fund, possibly causing the Fund's share price and total return to be reduced and fluctuate more than other types of investments. The lower the rating of a debt security, the greater its risks. In addition, these risks are often magnified for securities rated below investment grade, often referred to as “junk bonds,” and adverse changes in economic conditions or market perception are likely to cause issuers of these securities to be unable to meet their obligations to repay principal and interest to investors. Options Contracts – 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 Borrowings – 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 Investments (Limited Partnerships) – 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. 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. 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. Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 11 Item 9 – Disciplinary Information There are no legal, regulatory, or disciplinary events involving Naples Wealth Planning, LLC, or its management persons. We value the trust you place in us. As we advise all Clients, we encourage you to perform the requisite due diligence on any advisor or service provider with whom you partner. Our backgrounds are on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with our firm name or our CRD# 330316. Item 10 – Other Financial Industry Activities and Affiliations Broker-Dealer Affiliation As noted in Item 5, certain Advisory Persons are also Registered Representatives of AGWM. In an Advisory Person’s separate capacity as a Registered Representative, the Advisory Person will receive commissions for the implementation of recommendations for commissionable transactions. Clients are not obligated to implement any recommendation provided by an Advisory Person. Neither the Advisor nor its Advisory Persons will earn ongoing investment advisory fees in connection with any services implemented in an Advisory Person’s separate capacity as a Registered Representative. Insurance Agency Affiliations As noted in Item 5, certain Advisory Persons are also licensed insurance professionals. Implementation of insurance recommendations is separate and apart from an Advisory Person's role with the Advisor. As an insurance professional, an Advisory Person will receive customary commissions and other related revenues from the various insurance companies whose products are sold. An Advisory Person is not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents 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 Person or the Advisor. Use of Independent Managers As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment portfolio with one or more Independent Managers. The Advisor does not receive any compensation, nor does this present a material conflict of interest. The Advisor will only earn its wealth management fee as described in Item 5.A. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics NWP has implemented a Code of Ethics that defines our fiduciary commitment to each Client. This Code of Ethics applies to all persons associated with NWP (our “Supervised Persons”). The Code of Ethics was developed to provide general ethical guidelines and specific instructions regarding our duties to you, our Client. NWP and its personnel owe a duty of loyalty, fairness, and good faith towards each Client. It is the obligation of NWP 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 of Ethics covers a range of topics that address employee ethics and conflicts of interest. To request a copy of our Code of Ethics, please contact us at (239) 260-9386. B. Personal Trading with Material Interest NWP allows the purchase or sale of the same securities that may be recommended to and purchased on behalf of Clients. NWP 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. NWP does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients NWP allows the purchase or sale of the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities we recommend (purchase or sell) to you presents a potential conflict of interest that, as fiduciaries, we must disclose to you and mitigate through policies and procedures. As noted above, we have adopted a Code of Ethics, which addresses insider trading (material non-public information controls) and personal securities reporting procedures. When trading for personal accounts, Supervised Persons of NWP may Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 12 have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can potentially 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 NWP requiring reporting of personal securities trades by its employees for review by the Chief Compliance Officer (“CCO”). We have also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While NWP allows the purchase or sale of the same securities that may be recommended and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no time will NWP transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] NWP does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer or custodian (herein the "Custodian") to safeguard Client assets and authorize NWP to direct trades to this Custodian as agreed in the investment advisory agreement. Further, NWP does not have the discretionary authority to negotiate commissions on behalf of our Clients on a trade-by- trade basis. Where NWP does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients. NWP 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, and its overall reputation. Clients are not obligated to use the recommended Custodian and will not incur any extra fee or cost associated with using a Custodian not recommended by NWP. However, if the recommended Custodian is not engaged, NWP may be limited in the services it can provide comparable to other Clients. Further, as certain Advisory Persons are also Registered Representatives of AGWM, the Advisor may be limited in using other broker-dealers/custodians as AGWM must approve the use of any outside broker-dealer/custodian. NWP will recommend that Clients establish their account[s] at Charles Schwab & Co., Inc. (“Schwab”), a FINRA- registered broker-dealer and member SIPC. Schwab will serve as the Client’s “qualified custodian”. NWP 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 whereby an advisor enters into an agreement to place security trades with the broker in exchange for research and other services. NWP does not participate in soft dollar programs sponsored or offered by any broker-dealer. However, the Advisor does receive certain economic benefits from Charles Schwab. Please see Item 14 below. 2. Brokerage Referrals - NWP - does not receive any compensation from any third party in connection with the recommendation for establishing a brokerage account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where NWP will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective brokerage 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]). In selecting the Custodian, NWP 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 designated 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 Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 13 most favorable net results considering such factors as 1) price, 2) size of order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the broker. NWP will execute its transactions through an unaffiliated broker- dealer selected by the Client. NWP may aggregate orders in a block trade or trades when securities are purchased or sold through the same broker-dealer for multiple (discretionary) accounts. 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 particular Client accounts. Item 13 – Review of Accounts A. Frequency of Reviews Investments in Client accounts are monitored on a regular and continuous basis by Partners of NWP and periodically by the CCO. Formal reviews are generally conducted at least annually or more or less 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 or less 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 NWP 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 periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by NWP Participation in Institutional Advisor Platform: Charles Schwab NWP has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like NWP. As a registered investment advisor participating on the Schwab Advisor Services platform, NWP 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 potential 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. We receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab. In addition, Schwab has also agreed to pay for certain products and services for which we would otherwise have to pay once the value of our clients’ assets in accounts at Schwab reaches a certain size. [In some cases, a recipient of such payments is an affiliate of ours or another party which has some pecuniary, financial, or other interests in us (or in which we have such an interest).] You do not pay more for assets maintained at Schwab as a result of these arrangements. However, we benefit from the arrangement because the cost of these services would otherwise be borne directly by us. You should consider these conflicts of interest when selecting a custodian. The products and services provided by Schwab, how they benefit us, and the related conflicts of interest are described below. NWP also receives for a limited time financial assistance whereby Schwab reimburses the Advisor for certain expenditures including software and Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 14 compliance 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 NWP 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 potential conflict of interest. NWP believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. B. Compensation for Client Referrals Certain Clients may be referred to the Advisor by either an affiliated or unaffiliated party (herein "Promoter") and receive, directly or indirectly, compensation for the Client referral. In such instances, the Advisor will compensate the Promoter with a fee in accordance with Rule 206(4)-1 of the Advisers Act and any corresponding state securities requirements. Any such compensation shall be paid solely from the investment advisory fees earned by the Advisor and shall not result in any additional charge to the Client. Item 15 – Custody NWP does not accept or maintain custody of any Client accounts, except for the authorized deduction of the advisor’s fee. 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 NWP to utilize that Custodian for the Client’s security transactions. NWP encourages Clients to review statements provided by the account Custodian. 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 also have custody of those assets. In order to avoid additional regulatory requirements, the Advisor has adopted safeguards to ensure that the money movements are completed in accordance with the Client’s instructions. Item 16 – Investment Discretion NWP 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 NWP. 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 an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by NWP will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities NWP 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. Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 15 Item 18 – Financial Information Neither NWP, nor its management, have any adverse financial situations that would reasonably impair the ability of NWP to meet all obligations to its Clients. Neither NWP, nor any of its Advisory Persons, has been subject to a bankruptcy or financial compromise. NWP is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect fees of $1,200 or more for services to be performed six months or more in advance. Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 16 Privacy Policy Effective Date: March 11, 2024 Our Commitment to You Naples Wealth Planning, LLC (“NWP” 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. NWP (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. NWP 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? 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 Account applications and forms Investment questionnaires and suitability documents Transactional information with us or others 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. Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 17 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 NWP Wealth shares Client information with American Global Wealth Management, Inc. (“AGWM”). This sharing is due to the oversight AGWM has over certain Supervised Persons of the Advisor. You may also contact us at any time for a copy of the AGWM Privacy Policy. Marketing Purposes NWP 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 NWP 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]. No Not Shared Information About Former Clients NWP 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 Privacy 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 the Advisor at (239) 260-9386. Naples Wealth Planning, LLC 3301 Bonita Beach Road, Suite 308, Bonita Springs, FL 34103 Phone: (239) 260-9386 Page 18