Overview

Assets Under Management: $248 million
Headquarters: DALLAS, TX
High-Net-Worth Clients: 112
Average Client Assets: $4 million

Services Offered

Services: Financial Planning

Fee Structure

Primary Fee Schedule (ASCENTIS WEALTH MANAGEMENT, LLC)

MinMaxMarginal Fee Rate
$0 $1,000,000 1.50%
$1,000,001 $5,000,000 1.00%
$5,000,001 $10,000,000 0.90%
$10,000,001 and above 0.80%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $15,000 1.50%
$5 million $55,000 1.10%
$10 million $100,000 1.00%
$50 million $420,000 0.84%
$100 million $820,000 0.82%

Clients

Number of High-Net-Worth Clients: 112
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 78.24
Average High-Net-Worth Client Assets: $4 million
Total Client Accounts: 481
Discretionary Accounts: 383
Non-Discretionary Accounts: 98

Regulatory Filings

CRD Number: 330923
Last Filing Date: 2025-02-27 00:00:00
Website: https://bristallane.com

Form ADV Documents

Additional Brochure: ASCENTIS WEALTH MANAGEMENT, LLC (2025-08-04)

View Document Text
Part 2A of Form ADV: Firm Brochure Ascentis Wealth Management, LLC 5001 Spring Valley Rd, Suite 810W Dallas, TX 75244 July 2025 This brochure provides information about the qualifications and business practices of Ascentis Wealth, LLC. If you have any questions about the contents of this brochure, please contact our Chief Compliance Officer, Matthew Reynolds, at matthew.reynolds@ascentiswealth.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Ascentis Wealth Management is also available on the SEC’s website at www.adviserinfo.sec.gov. References herein to as a “registered investment adviser” or any reference to being “registered” does not imply a certain level of skill or training. Form ADV Part 2 Brochure Page 1 of 22 Item 2 Material Changes The Firm has rebranded from ORG Wealth Partners, LLC. To Ascentis Wealth Management, LLC The following is a summary of material changes made to this Brochure: The Chief Compliance Officer was updated from Justine Kidwell to Matthew Reynolds. The Firm’s ownership structure has changed, with Michael Mansur having majority ownership of Ascentis Operations, LLC, which is the parent company of Ascentis Wealth Management through a private Irrevocable Trust. Item 5 was updated to add a fee schedule. Item 12 was updated to remove Raymond James Financial and Prudential Investment Management. Form ADV Part 2 Brochure Page 2 of 22 Table of Contents Item 3 Contents Item 1 Cover Page .................................................................................................................................... 1 Item 2 Material Changes .......................................................................................................................... 2 Item 3 Table of Contents .......................................................................................................................... 3 Item 4 Advisory Business .......................................................................................................................... 5 A. Ascentis Wealth Management, LLC ................................................................................................... 5 B. Types of Advisory Services Offered ................................................................................................... 5 C. Tailored Relationships ....................................................................................................................... 7 D. Participation in Wrap Fee Programs .................................................................................................. 7 E. Assets Under Management ............................................................................................................... 7 Item 5 Fees and Compensation ................................................................................................................ 8 A. Ascentis Compensation .................................................................................................................... 8 B. Billing of Fees ................................................................................................................................. 10 C. Other Fees ..................................................................................................................................... 11 Item 6 Performance-Based Fees and Side-By-Side Management ........................................................... 11 Item 7 Types of Clients .......................................................................................................................... 11 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ...................................................... 11 A. Methods of Analysis and Investment Strategies ............................................................................. 11 B. Risk of Loss ..................................................................................................................................... 12 C. Other Fees ..................................................................................................................................... 14 Item 9 Disciplinary Information ............................................................................................................. 14 Item 10 Other Financial Industry Activities and Affiliations .................................................................. 15 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............. 15 A. Ascentis Wealth Management Code of Ethics ............................................................................... 15 B. Participation or Interest in Client Transactions ............................................................................... 15 C. Personal Trading ............................................................................................................................ 16 Item 12 Brokerage Practices ................................................................................................................ 16 A. Broker-Dealer Selection ................................................................................................................. 16 B. Trade Errors ................................................................................................................................... 20 C. Order Aggregation, Allocation, and Rotation Practices ................................................................... 20 Item 13 Review of Accounts ................................................................................................................ 21 Form ADV Part 2 Brochure Page 3 of 22 A. Periodic Reviews ............................................................................................................................ 21 Item 14 Client Referrals and Other Compensation .............................................................................. 21 A. Other Compensation...................................................................................................................... 21 B. Referrals......................................................................................................................................... 22 Item 15 Custody .................................................................................................................................. 22 Item 16 Investment Discretion ............................................................................................................ 22 Item 17 Voting Client Securities .......................................................................................................... 23 Item 18 Financial Information ............................................................................................................. 23 Form ADV Part 2 Brochure Page 4 of 22 Advisory Business Item 4 A. Ascentis Wealth Management, LLC Ascentis Wealth Management, LLC. (“Ascentis Wealth,” “Ascentis, “or the “Adviser”) is limited liability company formed on March 2, 2024. The Adviser is an investment adviser registered with the Securities and Exchange Commission (“SEC”) under the Investment Advisers Act of 1940, as amended (the “Investment Advisers Act”). The direct majority owner of Ascentis Wealth is Ascentis Operations, LLC. See Item 10 of this document for additional discussion concerning the firm’s affiliates. Our firm’s office is located at 5001 Spring Valley Rd, Suite 810W, Dallas, TX, 75244. B. Types of Advisory Services Offered Financial Planning The Adviser’s financial planning process begins with an intensive fact-finding session which helps the Adviser become familiar with the client’s current financial situation (including among other things, income taxes, investments, insurance, estate affairs and family circumstances), as well as their personal goals and priorities for the next several years. Then, working from this comprehensive information, the Adviser makes specific goal-oriented recommendations. The Adviser’s specific goal-oriented recommendations are designed to educate and allow a client to coordinate his/her financial affairs more efficiently, increase cash flow, prudently reduce income taxes, and attempt to improve his/her overall net worth. Once this has been discussed with the client, the recommendations that the client feels comfortable with are scheduled for implementation with specific deadlines to be met. The Adviser continues to assist the client based on an annual review of services in all applicable areas of financial planning including estate, retirement, cash flow and tax planning. Investment Consulting The Adviser works to provide institutional retirement plans and the plan sponsors with diversified investment options for plan participants to choose from. In addition, as requested by the plan sponsor, the Adviser shall provide plan participants with general information seminars and/or educational materials that describe the various investment alternatives available under the plan, information about investing in general, including information about different types of investments, such as allocation strategies, and historical returns. Interactive materials designed to help participants identify an appropriate investment strategy are provided. Investment Management We offer discretionary and non-discretionary investment management services. Investment management services offered by the Adviser are specifically tailored to meet the needs of each client. Prior to delivering investment advisory services, the Adviser will ascertain each client’s specific investment objective. The Adviser will allocate, or recommend that the client allocate, their investment assets consistent with the designated investment objective. Please note: It is always the client’s responsibility to promptly notify the Adviser if there is any change in their financial situation or investment objective. This notification of change allows the Adviser an opportunity to review, evaluate, or revise the previous recommendations or services. Managed Discretionary Assets If you engage our firm on a discretionary basis, we require you to grant us discretionary authority to manage your account. Discretionary authorization will allow our Investment Advisor Representatives (“IAR’s”) to weigh the Client’s objectives with current market conditions and act on a client’s account Form ADV Part 2 Brochure Page 5 of 22 without further authorization. Ascentis Wealth has engaged Ascentis Asset Management, LLC, the sub- adviser for certain client accounts. As discussed further- in Item 10, Ascentis Wealth Management, LLC is affiliated by common ownership with Ascentis Asset Management, LLC. Clients may impose reasonable restrictions on any of the Adviser’s investment advisory services at any time, but restrictions must be delivered to the Adviser in writing and must be signed by the client. Managed Non-Discretionary Assets In addition to providing investment management of client assets on a discretionary basis, the Adviser, for a separate and additional fee, provides certain limited services to clients with respect to “Managed Non- Discretionary Assets.” These services consist solely of the following: • The Adviser is available to consult with the client on a semi-annual basis (or more often if requested by the client) regarding Managed Non-Discretionary Assets. However, the client is solely responsible for all decisions and consequences on the client’s Managed Non-discretionary Assets, including decisions on whether to retain or sell all or a portion of the Managed Non- Discretionary Assets. This responsibility remains solely with the client regardless of whether any security is reflected on account reports prepared by the Adviser. • The Adviser is available to service Managed Non-Discretionary Assets, such as setting up and monitoring regular distributions and special one-time distribution requests. • The Adviser can process any trades on the Managed Non-Discretionary Assets, but only when requested to do so by the client. Upon receipt of any client’s request, The Adviser will endeavor, but cannot guarantee, that any such transaction will be affected on the day received or at any specific time or price. Limitations for Non-Discretionary Assets Clients that engage the Adviser on a non-discretionary investment advisory basis must be willing to accept that the Adviser cannot affect any account transactions without obtaining prior consent to any such transaction(s) from the client. Thus, in the event of a market correction during which the client is unavailable, Ascentis Wealth will be unable to affect any account transactions (as it would for its discretionary accounts) without first obtaining the client’s consent. Third-Party Money Mangers After the Adviser has gathered information about the client’s specific investment objective, the Adviser will assist the Client in selecting a Third-Party Money Manager (“TPMM”) to deliver an investment model (“strategy”) or manage a separate account for the Client. IAR’s utilize multiple factors in selecting a prudent TPMM to recommend to a client, including but not limited to performance, investment objectives, and fees. These factors are considered in relation to the Client’s specific investment objective to help determine the suitability of the TPMM. When a client engages a TPMM we recommend, we do not directly manage that portion of the Client’s portfolio assets and are not involved in selecting the securities to be bought and sold, or the timing of the same. The day-to-day portfolio management decisions are provided by the TPMM and then executed by us at the Client’s custodian or executed directly by the TPMM if managed in a separate account. In the event that the use of multiple TPMMs is recommended to a client, each TPMM has differing minimum account requirements as well as a variety of fee ranges. If a client uses a TPMM in a separate account, we periodically review the Client’s financial situation, objectives, and restrictions; and communicate relevant information to the TPMM and assist the client in understanding and evaluating the services provided by the TPMM. Some TPPMs maintain their own separate execution, clearing, and custodial relationships. If we determine that a selected TPMM is not managing the Client’s portfolio in a manner consistent with Form ADV Part 2 Brochure Page 6 of 22 the Client’s IPS and investment objectives, or if the financial situation of the Client changes, we recommend a new TPPM. Additional Services The Adviser may furnish advice on matters not involving securities, such as: Insurance Review & Planning Corporate Retirement Plan Guidance • Retirement Income Planning Withdrawal Rate Analysis • • Estate & Charitable Gift Planning • Business Successions • Personal Financial Planning • Education Planning • Cash Flow & Budgeting • Employee Benefits & 401(k) Guidance • Tax Planning C. Tailored Relationships At the Adviser, advisory services are tailored to the specific needs of each Client. Prior to providing advisory services, the Adviser will ascertain each Client’s investment goals and objectives. The Adviser then allocates and/or recommends that the client allocates investment assets consistent with the designated investment objective. The client may, at any time, impose reasonable restrictions on the Adviser’s services, but restrictions must be delivered to the Adviser in writing and must be signed by the Client. In performing services for the Client, the Adviser is not required to verify any information it received from the client or from the Client’s other professionals and the Adviser is expressly authorized by the Client to rely on this information. Each client is advised that it remains the Client’s responsibility to promptly notify the Adviser if there is ever any change in the Client’s financial situation or investment objectives for the purpose of reviewing, evaluating, or revising the Adviser’s previous recommendations or services to the Client. D. Participation in Wrap Fee Programs The Adviser offers services through both wrap fee programs and non-wrap fee programs. Certain other fees are not included in the wrap fee and are paid for separately by the client. These fees include custodial fees, charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses), mark- ups and mark-downs, spreads paid to market makers, fees for trades executed away from the custodian, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. These fees are not included within the wrap fee you are charged by our firm, and the client would be charged these fees if appliable. Please refer to the Adviser’s Wrap Fee Brochure for additional information. Generally, we consider wrap fee programs through which investment advisory services and execution of your transactions are provided for specified fees that are not based directly upon transactions in your account. Our firm and our investment team do not manage wrap fee accounts differently from other programs. E. Assets Under Management The Adviser Manages a total of $202,629,051 managed in a discretionary fashion, and the remainder is managed in a non- discretionary manner. Form ADV Part 2 Brochure Page 7 of 22 Fees and Compensation Item 5 The information below provides an overview of the fees and compensation we generally receive for the services we provide. Please refer to your agreement with Ascentis for information about the specific fees to be imposed with respect to your account and the other terms and conditions that will govern your relationship with Ascentis. Our fees are generally negotiable. Fees may vary because of negotiations, discussions and/or factors that may include, but are not limited to, the circumstances of the client, the size and scope of the overall client relationship, client investment guidelines, additional or differing levels of service, or as may be otherwise agreed with specific clients. A. Ascentis Compensation Financial Planning Fees Ascentis Wealth offers either hourly or fixed fee arrangements to all clients for its financial planning services. Fixed fees are computed based upon a good-faith estimate of the hours required to perform services. Ascentis attempts to maintain parity with hourly and fixed charges while allowing some flexibility in estimation, considering case complexity and client-specific circumstances. Financial planning fees are negotiated on an individual basis at the time of the engagement for such services. Factors considered in determining the fees charged generally include, without limitation, the type of financial planning services provided such as retirement planning, legacy planning, tax planning, insurance, and special needs planning. An initial meeting is scheduled with a prospective client at no cost or obligation. The purpose of the meeting is to inform the prospective client of the types of services the Adviser provides and to generally discuss what the client desires from such a financial planning relationship. If the prospective client is interested in exploring the Adviser’s services in more detail, the Adviser will review the prospective client’s recent income tax returns and make a listing of his/her assets and liabilities. At a subsequent session, the prospective client is given an idea of the specific value of pursuing this financial planning process and is quoted a fee for the financial planning services to be provided. The financial planning fee is quoted on a project basis and covers projected time and expenses associated in working with this client for a twelve-month period. This includes gathering data, developing the written plan, reviewing the plan with appropriate advisers, discussing the plan with the client, implementation, and continuing to review, monitor and update the client’s affairs throughout the ensuing twelve months. The financial planning fee is based upon several factors, including net worth, gross income, complexity of one’s financial affairs, and the time necessary to meet each individual client’s goals and priorities. Certain unforeseen expenses may not be included in the financial planning fee and would be billed directly. Once the client verbally agrees to the personal financial planning process, the process to develop the written documents begins. Once the financial plan is completed and the appropriate advisers have reviewed the plan, a meeting is scheduled to discuss the plan and the specific items to be implemented with the client. The client takes from this meeting the written plan. The client will be invoiced for the services provided. Payments are expected within 30 days of the invoice date through an approved payment method offered by Ascentis Wealth as outlined on the invoice. The financial planning fee shall be mutually agreed upon in advance by and between the client and Ascentis. Any such fee shall be separate from the asset-based investment management fee. The Adviser reserves the right to waive a portion of or the entire financial planning fee. Form ADV Part 2 Brochure Page 8 of 22 The agreement will remain in effect until terminated in writing by either party. Platform Fees When a client is invested with the Bridgeport platform, the Adviser receives compensation in the form of a fee, this fee is not shared with the advisor. Investment Management Fees The Adviser bases its annual investment management fee on a percentage of assets under management. The Adviser charges an annual fee of up to 2.00% of the assets under management. The Adviser may choose to charge a lower asset-based fee at its sole discretion. Fee Schedule The client agrees to pay the following fees: • The management fees are deducted on a quarterly or monthly basis. • Fees are determined by which program and Advisor the client chooses. Fee Percentage Rate Up to 1.50% Up to 1.00% Up to 0.90% Up to 0.80% Household Assets <$1MM $1MM – $5MM $5MM – $10MM $10MM – unlimited • Platform fees (e.g., Liberty Fi, Envestnet, etc.) • Investment management fees payable to third parties. Model portfolio advisors could include affiliates of Ascentis. o Ascentis Wealth may invest client assets in models that are created by affiliates of Ascentis Wealth and the affiliates could be compensated on models used by Ascentis Wealth clients. Fee Calculation Basis The value used to calculate the investment management fee will be based on the average daily balance computed at the close of business each trading day or the value of the assets on the last day of the prior quarter. Your specific billing will be referenced above and is detailed in your investment management agreement. Payment of Fees Ascentis Wealth generally requires clients to authorize the direct debit of advisory service fees from their accounts. However, certain exceptions may be granted, subject to Ascentis Wealth’s written consent, to permit clients to be billed directly for advisory service fees. The client may withdraw this authorization for direct debit of the advisory service fee at any time by notifying Ascentis Wealth or the custodian in writing. If the cash portion of an account is insufficient to pay the advisory service fee, Ascentis Wealth may direct the custodian to liquidate assets selected by Ascentis Wealth to pay such fees. Average Daily Balance Billing The figure used in the fee calculation is the average daily balance of the previous quarter computed at the close of business each trading day. In computing Average Daily Balance in the account, shares of any mutual funds are valued at their respective net asset value as calculated on the valuation date in accordance with each fund’s prospectus. The value of stocks, bonds, options, and other securities is the closing price provided by custodians and/or reputable pricing services. You should not deem valuation, for fee calculation purposes, as a guarantee with respect to marketability/liquidation value of those assets. Form ADV Part 2 Brochure Page 9 of 22 Last Day of the Previous Quarter Billing The figure used in the fee calculation is the value of assets on the last day of the previous quarter, as valued by the custodian. Payment of Fees The fees listed above are payable by the client to Ascentis Wealth Quarterly- in advance, based upon the fee calculation method detailed in the client’s investment management agreement for the previous quarter. Third-Party Money Manager Fees Fees charged by Third-Party Money Managers may be similar to, more or less, than fees assessed by Ascentis Wealth. The Client will pay any TPMM engaged pursuant to the foregoing fees charged by the managers, which are separate from and in addition to the Adviser’s fees. Clients referred to as a TPMM for the management of a separate account are directed to the disclosure documents. Negotiated Fees The Adviser, in its sole discretion, may reduce its investment management fee based upon certain factors, like anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, negotiations with client and other considerations. Other Fees Clients not participating in a wrap fee program will incur transaction charges for trades executed in their accounts. These transaction charges are separate from our fees and will generally be disclosed in the brokerage or custodian agreement in place with respect to your account. Clients may incur certain charges imposed by custodians, brokers, and other third parties such as custodial fees, deferred sales charges, odd- lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Also, clients will pay the following separately incurred expenses: charges imposed directly by an investment model, mutual fund, index fund, or ETF, which expenses and charges are generally disclosed in the fund's prospectus (e.g., fund management fees, distribution fees and other fund expenses). Clients may be responsible for paying fees charged by sub-advisers, money managers, Platforms, and/or Platform managers that have been engaged to manage their account as described in the investment management agreement. Such charges, fees, and commissions are exclusive of, and in addition to, our fee. Ascentis, or our affiliate, receives a portion of fees charged by Platforms and for certain investment models. Item 10 further describes this arrangement, and the conflicts of interest presented. This brochure describes our non-wrap fee advisory services; clients utilizing our wrap fee portfolio management should see the separate Wrap Fee Program Brochure for additional details regarding third party fees. Item 12 further describes the factors that we consider in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation (e.g., commissions). B. Billing of Fees Ascentis Wealth’s investment management fees shall be assessed quarterly, in advance, based upon the fee calculation method detailed in the client’s investment management agreement for the prior quarter. New accounts will be assessed as a prorated fee dependent upon the number of days remaining in the quarter. The Adviser clients must provide their consent in advance to direct debiting of investment management fees from their custodial account. The Investment Advisory Agreement and the custodial/clearing Form ADV Part 2 Brochure Page 10 of 22 agreement authorize the custodian to debit the client account for the amount of the Adviser’s investment management fee, and to directly remit that investment management fee to the Adviser in compliance with regulatory procedures. The Adviser may send each client an itemized fee invoices each quarter – please see Item 15 for additional information. In the limited event that the Adviser bills the client directly, payment in full is expected upon presentation of the invoice. In the event an agreement is terminated, the client will receive a prorated refund for fees paid in advance. C. Other Fees Unless clients direct otherwise or an individual client’s circumstances require, the Adviser generally recommends one of several unaffiliated custodians (e.g., Charles Schwab & Co., Sanders Morris Harris. etc.) serve as the broker-dealer/custodian for client investment accounts. Broker dealers such as those listed above may charge brokerage commissions and/or transaction fees for affecting certain securities transactions. For example, these custodians may charge commissions for individual equity and fixed income securities transactions, or fees may be charged for certain no-load mutual fund transactions. In addition to the Adviser’s investment management fee, custodial brokerage commissions and/or transaction fees, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). Performance-Based Fees and Side-By-Side Management Item 6 Ascentis Wealth does not advise any client accounts that are subject to performance-based fee arrangements. Types of Clients Item 7 The Adviser predominantly offers its services to individuals, high net worth individuals, pension and profit-sharing plans and participants, trusts, estates, charitable Organizations, corporations, or business entities. The Adviser may reduce or waive its minimum asset requirement based upon certain factors, like anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, negotiations with client and other considerations. Other exceptions may apply to employees of the Adviser and their relatives, or relatives of existing clients. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis and Investment Strategies The Adviser’s security analysis methods may include fundamental analysis, technical analysis, charting and cyclical analysis. The main sources of information for analysis include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Additional research tools and sources of information that the Adviser may use include mutual fund and stock information provided by unaffiliated third parties (e.g., Morningstar, etc.) and many other reports located on the Internet using the World Wide Web. The Adviser may utilize the following investment strategies when implementing investment advice given to clients: Form ADV Part 2 Brochure Page 11 of 22 Long Term Purchases: (securities held at least a year) Short Term Purchases: (securities sold within a year) Trading: (securities sold within thirty (30) days) • • • • Options (contract for the purchase or sale of a security at a predetermined price during a specific period of time) Strategic and Tactical Asset Allocation may be utilized with domestic mutual funds, exchange-traded funds, or stocks and bonds as the core investments. Global mutual funds, sector funds and specialty exchange-traded funds may be added as satellite positions. Portfolios may be further diversified among large, medium, and small sized investments in an effort to control the risk associated with traditional markets. Investment strategies designed for each client are based upon specific objectives stated by the client during consultations. Clients may change their specific objectives at any time. Each client executes an Investment Policy Statement that documents their specific objectives and their desired investment strategy. Please Note: Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy recommended or undertaken by the Adviser will be profitable or equal any specific performance level. Investing in securities involves risk of loss that clients should be prepared to bear. B. Risk of Loss Risk is inherent in any investment in securities and the Adviser does not guarantee any level of return on a client’s investments. There is no assurance that a client’s investment objectives will be achieved. A client may be subject to certain risks, including, but not limited to, the risks described below. The risks discussed below vary by investment style or strategy and may or may not apply to a client. A client should also review the prospectuses or other disclosure documents for the securities purchased for the client’s account, as they will contain important information about the risks associated with investing in such securities. Investment strategies recommended by the Adviser may also be subject to some or all of the following types of risk: • Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. • • Market Risk: The price of a security, bond, ETF, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic, and social conditions may trigger market events. Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. • Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities. • Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They may carry a higher risk of profitability Form ADV Part 2 Brochure Page 12 of 22 • than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many investors are interested in buying or selling a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. • Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. • Risks of Investments in ETFs, Mutual Funds, and Other Investment Pools: Ascentis Wealth may invest client portfolios in ETFs, mutual funds, and other investment pools (“Funds”). Investments in Funds are generally less risky than investing in individual securities because of their diversified portfolios; however, these investments are still subject to risks associated with the markets in which they invest. In addition, Funds’ success will be related to the skills of their managers and their performance in managing their Funds. Registered Funds are also subject to risks due to regulatory restrictions applicable to registered investment companies under the Investment Company Act of 1940, as amended. • Fixed Income Risks: Ascentis Wealth may invest portions of client assets directly in fixed income instruments, such as bonds and notes, or may invest in Funds that invest in bonds and notes. While investing in fixed income instruments, either directly or through Funds, is generally less volatile than investing in stock (equity) markets, fixed income investments nevertheless are subject to risks. These risks include, without limitation, interest rate risks (risks that changes in interest rates will devalue the investments), credit risks (risks of default by borrowers), or maturity risk (risks that bonds or notes will change value from the time of issuance to maturity). Ascentis Wealth may invest portions of client assets into securities that are rated below investment grade (commonly known as “high yield” or “junk bonds”). Securities which are in the lower-grade categories generally offer a higher current yield than is offered by higher-grade securities of similar maturities, but they also generally involve greater risks, such as greater credit risk, greater market risk and volatility, and greater liquidity concerns. These investments are generally considered to be speculative based on the issuer’s capacity or incapacity to pay interest and repay principal. • Financial Planning Risks: Financial planning is inherently speculative, and Ascentis Wealth makes no guarantee regarding the success or feasibility of any financial plan. The information forming the basis of any financial plan will be derived from sources that Ascentis Wealth believes are reliable, including information provided by the client, and the accuracy of such information is not guaranteed or independently verified by the Advisor. Certain financial planning services may include educational information regarding the effect of taxes or recommendations with respect to insurance coverage types and amounts. Clients should understand that this tax and insurance information is general in nature. Nothing recommended or outlined by Ascentis Wealth should be used by a client as a substitute for competent legal, accounting, or tax counsel provided by the client’s personal attorney, accountant, and/or tax advisor. Additionally, Ascentis Wealth strongly recommends that each client reviews each area of potential and/or actual insurance coverage need with the client’s insurance agent to ensure that adequate coverage exists. • Cybersecurity Risk: As technology becomes more integrated into Ascentis Wealth operations, Ascentis Wealth will face greater operational risks through breaches in cybersecurity. A breach in cybersecurity refers to both intentional and unintentional events that may cause Ascentis Wealth to lose proprietary information, suffer data corruption, or lose operational capacity. This in turn could cause Ascentis Wealth to incur regulatory penalties, reputational Form ADV Part 2 Brochure Page 13 of 22 damage, additional compliance costs associated with corrective measures, and/or financial loss. Cybersecurity threats may result from unauthorized access to Ascentis Wealth digital information systems (e.g., through “hacking” or malicious software coding) but may also result from outside attacks such as denial-of-service attacks (i.e., efforts to make network services unavailable to intended users). In addition, because Ascentis Wealth works closely with third- party service providers (e.g., administrators, transfer agents, and custodians), cybersecurity breaches at such third-party service providers may subject Ascentis Wealth to many of the same risks associated with direct cybersecurity breaches. The same is true for cybersecurity breaches at any of the issuers in which Ascentis Wealth may invest. While Ascentis Wealth and their third- party service providers have established information technology and data security programs and have in place business continuity plans and other systems designed to prevent losses and mitigate cybersecurity risk, there are inherent limitations in such plans and systems, including the possibility that certain risks have not been identified or that cyber-attacks may be highly sophisticated. • Private Equity (PE) Funds and Private placement Securities Risks are inherently illiquid; they cannot be easily sold or exchanged for cash without a substantial loss in value. Investors are usually required to commit their capital for extended periods. Private equity funds typically charge high fees, including management fees and performance fees (carried interest). These fees can erode returns, especially if the fund's performance does not meet expectations. Private Equity funds are subject to higher degrees of risk and may not be suitable for all investors. Their performance is heavily dependent on the skill and experience of the management team. Private equity funds commonly use leverage (borrowed funds) to enhance returns, which can increase the potential for significant losses, especially in downturns. In addition, Private Equity investments often lack transparency. Detailed information about the fund's operations and investments is not readily available, making it challenging to evaluate the valuations of private companies. • Private Placement Securities have similar characteristics and carry risks akin to those of Private Equity Funds. However, Private Placements are typically offered to institutional clients or accredited investors. Please Note: In light of these risks of loss and potentially enhanced volatility, clients may direct the Adviser, in writing at any time, not to employ any or all of the investment strategies recommended by Ascentis Wealth for their account. C. Other Fees Unless clients direct otherwise or an individual client’s circumstances require, the Adviser generally recommends one of several unaffiliated custodians (e.g., Charles Schwab & Co., Sanders Morris Harris etc.) serve as the broker-dealer/custodian for client investment accounts. Broker dealers such as those listed above may charge brokerage commissions and/or transaction fees for affecting certain securities transactions. For example, these custodians may charge commissions for individual equity and fixed income securities transactions, or fees may be charged for certain no-load mutual fund transactions. In addition to the Adviser’s investment management fee, custodial brokerage commissions and/or transaction fees, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). Disciplinary Information Item 9 Investment Advisors are required to disclose legal or disciplinary events that are material to a client’s or prospective client’s evaluation of the Advisor’s business or the integrity of the Advisor’s management. Ascentis Wealth has no such disclosures to provide. Form ADV Part 2 Brochure Page 14 of 22 Other Financial Industry Activities and Affiliations Item 10 The Adviser is not registered as a securities broker-dealer, futures commission merchant, commodity pool operator or commodity trading advisor. Some representatives of the firms are also registered representatives of Broker Dealers. Advisors that are also registered representatives of a broker dealer can offer securities and receive normal and customary commissions as a result of securities transactions. Therefore, a conflict of interest would arise as these commissionable securities sales could create an incentive to recommend products based on the compensation they would earn and may not necessarily be in the best interests of the clients. Affiliated Firms Ascentis Wealth is under common control with: • Ascentis Asset Management, LLC • Golden State Equity Partners, LLC • ORG Partners These affiliates may offer services to our clients. No client is required to use any affiliate, and all recommendations are made in the client’s best interest. Insurance Sales Many of the financial professionals at our firm are licensed insurance agents. Ascentis Wealth, at times, recommends the use of various insurance products where we believe it is in your best interest. You should be aware that these services pay a commission or other compensation and present a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. Ascentis Wealth always seeks to act in the best interest of the client; including the sale of commissionable products to advisory clients, and we will disclose the commission prior to the sale. You are in no way required to implement the plan through any representative of Ascentis Wealth in such an individual’s capacity as an insurance agent. Management Disclosures Matthew Reynolds, Outsourced Chief Compliance Officer, of Ascentis Wealth. Matthew is President of Bristal Lane Group, and which performs consulting services for broker dealers and registered investment advisors, including registrant. Matthew is also President and CFO for Thurston Capital, LLC, which is parent of Bristal Lane Group. Michael Mansur, President of Ascentis Wealth. Michael has ownership in Ascentis Operations, LLC, which is the direct owner of Ascentis Wealth, Ascentis Asset, Golden State Equity Partners, and ORG Partners. Clint Sorenson, Chief Investment Officer, has ownership in Ascentis Operations LLC, which is the direct owner of Ascentis Wealth, Ascentis Asset, Golden State Equity Partners, and ORG Partners. Code of Ethics, Participation or Interest in Client Transactions and Personal Item 11 Trading A. Ascentis Wealth Code of Ethics We have adopted a Code of Ethics pursuant to Advisers Act Rule 204A-1. A basic tenet of our Code of Ethics is that the interests of clients are always placed first. The Code of Ethics includes standards of business conduct requiring Access Persons to comply with the federal securities laws and the fiduciary duties an investment adviser owes to its clients. The Code of Ethics also requires that all Access Persons comply with ethical restraints relating to clients and their accounts, including restrictions on gifts and provisions intended to prevent violations of laws prohibiting insider trading. The goal of our Code of Ethics is to ensure that personal investing activities by our employees are Form ADV Part 2 Brochure Page 15 of 22 consistent with our fiduciary duty to its clients. The Code of Ethics includes standards of business conduct requiring Access Persons to comply with the federal securities laws and the fiduciary duties an investment adviser owes to its clients. The Code applies to all Access persons that are considered to be supervised by Ascentis Wealth . Personnel are considered to be Access Persons under the Code including the following: • Directors, officers, and partners of the Firm (or other persons occupying a similar status or performing similar functions). • Employees of the Firm; • Any other person who provides advice on behalf of the Firm and is subject to the Firm’s supervision and control. Our Code of Ethics is available to you upon request. You may obtain a copy of our Code of Ethics by contacting our Chief Compliance Officer, Matthew Reynolds, at matthew.reynolds@ascentiswealth.com. Participation or Interest in Client Transactions Ascentis Wealth and/or its representatives may engage in securities transactions for their own accounts, including the same or related securities that are recommended to or owned by clients of the Adviser. Because Advisors can invest in the same securities as clients, there is a possibility that an Advisor will benefit from a client’s trading activity in a security held by the Advisor. B. Personal Trading To address the potential for conflict of interests, the Adviser has adopted a Code that applies to its representatives who have access to non-public information relating to advisory client accounts (“Access Persons”). The Code prohibits Access Persons from using knowledge about advisory client account transactions to profit personally, directly, or indirectly, by trading in his/her personal accounts. To help monitor any conflict of interest, all Access Persons are required to submit quarterly personal securities transactions and annual holdings reports for review by the Chief Compliance Officer. or delegated compliance personnel. Brokerage Practices Item 12 A. Broker-Dealer Selection We seek to recommend a custodian/broker who will hold your assets and execute transactions on terms that are overall most advantageous when compared with other available providers and their services. We consider a wide range of factors, including these: • Combination of transaction execution services along with asset custody services (generally without a separate fee for custody) • Capability to execute, clear, and settle trades (buy and sell securities for your account) • Capabilities to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) • Breadth of investment products made available (stocks, bonds, mutual funds, exchange traded funds (ETFs), etc.) • Availability of investment research and tools that assist us in making investment decisions • Quality of services • Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate them • Reputation, financial strength, and stability of the provider • Their prior service to us and our other clients • Availability of other products and services that benefit us • Ascentis Wealth does not maintain custody of your assets that we manage, although we may be deemed Form ADV Part 2 Brochure Page 16 of 22 to have custody of your assets if you give us authority to withdraw assets from your account (see Item 14 – Custody, below). Your assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. We recommend that our clients use Charles Schwab & Co., Inc. (Schwab), and Sanders Morris Harris (“SMH”), these firms are SEC-registered broker-dealers, members of FINRA/SIPC. Schwab and SMH are qualified custodians. We are independently owned and operated and are not affiliated with these broker dealers. We also recommend the brokerage and custodial services of Sanders Morris Harris, LLC (“SMH”), member FINRA/SIPC. SMH is an unaffiliated SEC-registered broker-dealer and FINRA member. Research and Other Soft Dollar Benefits. The Adviser does not receive research in addition to execution services from a broker-dealer in connection with its clients’ securities transactions. These research benefits are commonly referred to as “soft dollar benefits.” The Adviser may from time to time receive generic market commentaries or market research from broker-dealer firms. However, the receipt of those materials is not tied to the execution of client transactions. The Adviser seeks to select broker-dealers based upon the broker’s or dealer’s ability to provide the best execution, and the Adviser will not cause clients to pay commissions (or markups or markdowns) higher than those charged by other broker-dealers for the purpose of obtaining soft dollar benefits. Your Brokerage and Custody Costs We recommend the brokerage and custodial services of Schwab Advisor Services division of Charles Schwab & Co., Inc. (“Schwab”), a registered broker-dealer, member SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. The final decision to custody assets with Schwab is at the discretion of our clients, including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA accountholder. We are independently owned and operated and not affiliated with Schwab. Schwab provides us with access to its institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to advisors. Schwab’s services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. Our firm and/or our supervised persons receive benefits. Schwab also makes available to Ascentis other products and services that benefit us but may not benefit our clients’ accounts. These benefits may include national, regional or Ascentis specific educational events organized and/or sponsored by Schwab Advisor Services. Other potential benefits may include occasional business entertainment of personnel of Ascentis by Schwab Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist us in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), provide research, pricing information and other market data, facilitate payment of Ascentis’ fees from its clients’ accounts, and assist with back- office training and support functions, recordkeeping, and client reporting. Many of these services Form ADV Part 2 Brochure Page 17 of 22 generally may be used to service all or some substantial number of Ascentis’ accounts, including accounts not maintained at Schwab Advisor Services. Schwab Advisor Services also makes available to Ascentis other services intended to help Ascentis manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance, and marketing. In addition, Schwab makes available, arranges and/or pays vendors for these types of services rendered to Ascentis by independent third parties. Schwab Advisor Services may discount or waive fees they would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to Ascentis. Sanders Morris Harris: Our firm recommends that clients establish brokerage accounts with the Sanders Morris Harris (“SMH”), a registered broker-dealer, member SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. The final decision to custody assets with SMH is at the discretion of the client, including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA accountholder. Ascentis is independently owned and operated and not affiliated with SMH. SMH provides Ascentis with access to trading and custody services, which are typically not available to SMH retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to advisors. SMH’s services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. SMH also makes available to Ascentis other products and services that benefit Ascentis but may not benefit its clients’ accounts. These benefits may include national, regional or Ascentis specific educational events organized and/or sponsored by SMH Services. Other potential benefits may include occasional business entertainment of personnel of Ascentis by SMH Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. While, as a fiduciary, we endeavor to act in our clients’ best interests, our recommendation that clients maintain their assets in accounts at Schwab/SMH may be based in part on the benefit to Ascentis of the availability of some of the foregoing products and services and other arrangements and not solely on the nature, cost or quality of custody and brokerage services provided by Schwab/SMH, which creates a potential conflict of interest. Brokerage for Client Referrals We do not receive client referrals from broker-dealers in exchange for cash or other compensation, such as brokerage services or research. Our affiliate, Ascentis Asset Management, does have a fee sharing agreement with SMH that allows that entity to receive a share of the revenue that SMH earns from margin loan spreads and remarketing fees from money market-sweep products generated by clients referred to SMH. Although Ascentis does not receive compensation directly, this fee sharing agreement does benefit our affiliate and as such creates a conflict when we refer to clients to SMH. Form ADV Part 2 Brochure Page 18 of 22 Directed Brokerage The Adviser will comply with any guidelines and/or limitations reasonably requested by a client relating to brokerage for the client’s account that are contained in the client’s investment management agreement. when possible, the Adviser will also observe any non-binding statement of client preferences with respect to brokerage direction. If a client directs the Adviser to use a particular broker-dealer for execution of the client’s trade orders (a “directed brokerage arrangement”), and the Adviser agrees to the arrangement, a client should understand that the Adviser may be unable to achieve best execution for the client’s transactions. Any costs related to the directed brokerage arrangement are not included in the Adviser’s fee, and the client is solely responsible for monitoring, evaluating, and reviewing the arrangement with the directed broker- dealer and paying any commissions or markups or markdowns or other costs imposed by the directed broker-dealer. Additionally, the Adviser generally will not aggregate the client’s directed brokerage trade orders with orders for other clients of the Adviser or include such orders in its trade rotation process. If the Adviser aggregates a client’s directed brokerage trade orders with trade orders for other clients of the Adviser, the Adviser may employ the use of “step-outs” to satisfy the client’s directed brokerage arrangement. A “step-out” occurs when an executing broker executes the trade and then “steps out” the trade to a clearing broker (which would be the directed broker-dealer in a directed brokerage arrangement) that confirms and settles the trade. In such a case, a client will bear the costs of any commissions, markups or markdowns imposed by the executing broker-dealer in addition to the costs of any commissions, markups or markdowns imposed by the directed broker-dealer. If a client directs the Adviser to use a particular broker-dealer, and if the broker-dealer referred the client to the Adviser or if the particular broker-deal refers other clients to the Adviser in the future, the Adviser may benefit from the client’s directed brokerage arrangement. Because of these potential benefits, the Adviser may have an economic interest in having the client continue the directed brokerage arrangement. The benefits that the Adviser receives may conflict with the client’s interest in having the Adviser recommend that the client utilize another broker-dealer to execute some or all transactions for the client’s account. Before directing the Adviser to use a particular broker-dealer, a client should carefully consider the possible costs or disadvantages of directed brokerage arrangements. B. Trade Errors The Firm nor its Advisors will share in any gains resulting from the trade error. The Custodians Charles Schwab is in the practice of donating trade error gains to a charity of their choice. Should the trade error result in a loss, the Firm will charge back the losses to the Advisor. C. Order Aggregation, Allocation, and Rotation Practices In order to seek best execution for clients, the Adviser may aggregate contemporaneous buy and sell orders for the accounts over which it has discretionary authority. This practice of bunching trades may enable the Adviser to obtain more favorable execution, including better pricing and enhanced investment opportunities, than would otherwise be available if orders were not aggregated. Bunching transactions may also assist the Adviser in potentially avoiding an adverse effect on the price of a security that could result from simultaneously placing a number of separate, successive, or competing, client orders. It is within the Adviser’s sole discretion to bunch transactions and its decision is subject to its duty to seek best execution. The Adviser will aggregate a client’s trade orders only when the Adviser deems it to be Form ADV Part 2 Brochure Page 19 of 22 appropriate and in the best interests of the client and permitted by regulatory requirements. All advisory clients participating in a bunched transaction will receive the same execution price for the security bought or sold. Average prices may be used when allocating purchases and sales to a client’s accounts because such securities may be purchased and sold at different prices in a series of bunched transactions. As a result, the average price received by a client may be higher or lower than the price the client may have received had the transaction been effected for the client independently from the bunched transaction. In addition, a client’s transaction costs may vary depending upon, among other things, the type of security bought or sold, and the commission or markup or markdown charged by the executing broker-dealer. The amount of securities available in the marketplace, at a particular price at a particular time, may not satisfy the needs of all clients participating in a bunched transaction and may be insufficient to provide full allocation across all client accounts. To address this possibility, the Adviser has adopted trade allocation policies and procedures that are designed to make securities allocations to discretionary client accounts in a manner such that all such clients receive fair and equitable treatment. If a bunched transaction cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day will generally be allocated pro rata among the clients participating in the bunched transaction. Adjustments to this pro rata allocation may be made, at the discretion of the Adviser, to take into consideration account specific investment restrictions, undesirable position size, account portfolio weightings, client tax status, client cash positions and client preferences. Adjustments may also be made to avoid a nominal allocation to client accounts. When the Adviser is not able to aggregate trades, the Adviser generally uses a trade rotation process that is designed to be fair and equitable to its clients. Item 13 Review of Accounts A. Periodic Reviews IARs are required to conduct quarterly reviews of client statements to ensure 1) the statement is alignment with the Investor Advisory Agreement and agreed contractual fee schedule, 2) the clients’ accounts are in line with their investment objectives, appropriately positioned based on market conditions, and investment policies, if applicable. On an annual basis, Ascentis monitors client accounts to ensure IARs are adhering to the requirements noted above. Ascentis does not provide written reports to clients, however, IARs may create consolidated-performance statements. It is important to note the custodian’s statements supersede any reports generated by your IAR. We may review client accounts more frequently than described above. Among the factors that may trigger an off-cycle review include major market or economic events, the client’s life events, or requests by the client. Financial Planning clients do not receive reviews of their written plans unless they take action to schedule a financial consultation with us. We do not provide ongoing services to financial planning clients, but are willing to meet with such clients upon their request to discuss updates to their plans, changes in their circumstances, etc. Financial Planning clients do not receive written or verbal updated reports regarding their financial plans unless they separately contract with us for a post-financial plan meeting or update to their initial written financial plan. Form ADV Part 2 Brochure Page 20 of 22 Client Referrals and Other Compensation Item 14 A. Other Compensation Custodians As stated above, we recommend that clients establish brokerage accounts with the Schwab, and SMH, to maintain custody of clients’ assets and to effect trades in their accounts. The final decision to custody assets with these firms is at the discretion of our clients, including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA accountholder. These firms may provide us with access to its institutional trading and custody services, which are typically not available to retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to advisors. These services may include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. These firms may also make available to Ascentis other products and services that benefit us but may not benefit our clients’ accounts. These benefits may include national, regional or Ascentis specific educational events organized and/or sponsored by these firms. Other potential benefits may include occasional business entertainment of personnel of Ascentis by the above firms, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. These products and services assist us in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), provide research, pricing information and other market data, facilitate payment of Ascentis’ fees from its clients’ accounts, and assist with back- office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of Ascentis’ accounts, including accounts not maintained by the above firms. These firms may also make available to Ascentis other services intended to help Ascentis manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance, and marketing. In addition, the above firms may make available, arrange and/or pay vendors for these types of services rendered to Ascentis by independent third parties. The above firms may discount or waive fees they would otherwise charge for some of these services or pay all or a part of the fees of a third- party providing these services to Ascentis. Our affiliate, Ascentis Asset Management, does have a fee sharing agreement with SMH that allows that entity to receive a share of the revenue that SMH earns from margin loan spreads and remarketing fees from money market-sweep products generated by clients referred to SMH. Although Ascentis does not receive compensation directly, this fee sharing agreement does benefit our affiliates and as such creates a conflict when we refer to clients to SMH. While, as a fiduciary, we endeavor to act in our clients’ best interests, our recommendation that clients Form ADV Part 2 Brochure Page 21 of 22 maintain their assets in accounts at any of the above custodians may be based in part on the benefit to Ascentis, or it’s affiliates, of the availability of some of the foregoing products and services and other arrangements and not solely on the nature, cost or quality of custody and brokerage services provided by Schwab or SMH which creates a potential conflict of interest. B. Referrals Ascentis Wealth may provide compensation to individuals who refer clients in some instances. When applicable, the compensation paid is a percentage of the client’s fee payments or the value of the client’s account. The amount of compensation will vary, with the specific level determined based upon consideration of various factors. Ascentis Wealth may pay these fees to unaffiliated solicitors which they have entered into a written agreement with. Custody Item 15 Pursuant to Rule 206(4)-2 under the Advisers Act, because we may directly deduct advisory fees from client accounts as part of our billing process, we are deemed to have limited custody of client funds. The qualified custodian you hold your assets with maintains actual custody of your assets. You will receive account statements directly from the custodian at least Quarterly. They will be sent to the email or postal mailing address you provided to the custodian. You should carefully review those statements promptly when you receive them. Investment Discretion Item 16 Clients have the option of providing our firm with investment discretion on their behalf, pursuant to an executed investment advisory client agreement. By granting investment discretion, we are authorized to execute securities transactions including the selection and amount of securities to be purchased or sold for your account(s) without obtaining your consent or approval prior to each transaction. Limitations may be imposed by the client in the form of specific constraints on any of these areas of discretion with our firm's written acknowledgment. Voting Client Securities If a client enters into non-discretionary arrangements with Ascentis, we will obtain your approval prior to the execution of any transactions for your account(s). Clients have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis. Item 17 We do not and will not accept the proxy authority to vote client securities. Clients will receive proxies or other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent to our firm, we will forward them on to you and ask the party who sent them to mail them directly to you in the future. Clients may call, write, or email us to discuss questions they may have about particular proxy votes or other solicitations. Financial Information Item 18 Ascentis Wealth does not require prepayment of more than $1,200 in fees and for more than six months in advance, does not take custody of client funds or securities and does not have a financial condition that is likely to impair our ability to meet our commitments to our clients. Form ADV Part 2 Brochure Page 22 of 22

Additional Brochure: ASCENTIS WEALTH WRAP BROCHURE (08.2025) (2025-08-04)

View Document Text
Item 1 Cover Page Wrap Fee Program Brochure Ascentis Wealth Management, LLC 5001 Spring Valley Dallas, TX 75244 214-440-3909 August 2025 This wrap fee program provides information about the qualifications and business practices of Ascentis Wealth Management, LLC If you have any questions about the contents of this brochure, please contact our Chief Compliance Officer, Matthew Reynolds at matthew.reynolds@ascentiswealth.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Ascentis Wealth Management is also available on the SEC’s website at www.adviserinfo.sec.gov. References herein to Ascentis Wealth Management, LLC as a “registered investment adviser” or any reference to being “registered” does not imply a certain level of skill or training. Page 1 of 17 Wrap Fee Program Brochure You may obtain a current copy of the Form CRS and our Form ADV Part 2 brochure at http://www.orgpag.com. Item 2 Material Changes The Firm has rebranded from ORG Wealth Partners, LLC. To Ascentis Wealth Management, LLC The following is a summary of material changes made to this Brochure: The Chief Compliance Officer was updated from Justine Kidwell to Matthew Reynolds. The Firm’s ownership structure has changed, with Michael Mansur having majority ownership of Ascentis Operations, LLC, which is the parent company of Ascentis Wealth Management through a private Irrevocable Trust. Form ADV Part 2 Brochure Page 2 of 17 Form ADV Part 2 Brochure Page 3 of 17 Table of Contents Item 3 Contents Item 1 Cover Page ................................................................................................................................. 1 Item 2 Material Changes ....................................................................................................................... 2 Item 3 Table of Contents ....................................................................................................................... 3 Item 4 Services, Fees and Compensation .............................................................................................. 4 A. Description of Services .................................................................................................................... 4 B. Contribution Cost Factors ............................................................................................................... 4 C. Additional Fees ................................................................................................................................ 5 D. Compensation of Client Participation .............................................................................................. 5 Item 5 Account Requirements and Types of Clients............................................................................... 5 Item 6 Performance-Based Fees and Side-By-Side Management ........................................................... 5 A. Selecting/Reviewing Portfolio Managers ......................................................................................... 5 B. Related Persons .............................................................................................................................. 6 C. Advisory Business ............................................................................................................................ 6 Item 7 Client Information Provided to Portfolio Managers ................................................................. 11 Item 8 Client Contact with Portfolio Manager ..................................................................................... 11 Item 9 Additional Information ............................................................................................................. 12 A. Disciplinary Action and Other Financial Industry Activities ........................................................... 12 B. Code of Ethics, Client Referrals, and Financial Information ........................................................... 13 Form ADV Part 2 Brochure Page 4 of 17 Services, Fees, and Compensation Item 4 A. Description of Services Ascentis Wealth Management, LLC (Ascentis Wealth”) participates in, and sponsors wrap fee programs, which means Ascentis Wealth will wrap transaction fees for wrap fee portfolio management accounts. Ascentis Wealth will charge clients one fee and pay all transaction fees using the fee collected from the client. Accounts participating in the wrap fee program are not charged higher advisory fees based on trading activity, but clients should be aware that Ascentis Wealth has an incentive not to place transaction orders in those accounts since doing so increases its transaction costs. Thus, an incentive exists to place trades less frequently in a wrap fee arrangement. Certain other fees are not included in the wrap fee and are paid for separately by the client. Clients may pay custodial fees, charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses), mark-ups, mark- downs, spreads paid to market makers, fees for trades executed away from the custodian, wire transfer fees, other fees and taxes on brokerage accounts and securities transactions. These fees are not included in the wrap-fee you are charged by our firm. The fee schedule is set forth below: Total Assets Under Management All Assets Annual Fees Up to 2.00% These fees are negotiable depending upon the needs of the client and complexity of the situation, the final fee schedule will be reflected in the advisory contract. Advisory fees are either based off the market value on the last day of the previous quarter or assessed quarterly based on the average daily value of the Portfolio assets over the previous calendar quarter. Refer to specific client agreement for agreed calculation details. After Ascentis Wealth pays transaction fees, Ascentis Wealth generally receives around 90% of the advisory fee. Advisory fees are withdrawn directly from the client’s accounts with client written authorization. Fees are paid quarterly in advance. Refunds are given on a prorated basis, based on the number of days remaining in the billing period on the effective date of termination. The fee refunded will be the balance of the fees collected in advance minus the daily rate* times the number of days in the billing period up to and including the effective date of termination. (*The daily rate is calculated by dividing the annual fee by 365.) Clients may terminate the contract without penalty, for a full refund, within five business days of signing the contract. Thereafter, clients may terminate the contract with thirty days’ written notice. B. Contribution Cost Factors The program may cost the client more or less than purchasing such services separately. There are several factors that bear upon the relative cost of the program, including the trading activity in the client’s account, the adviser’s ability to aggregate trades, and the cost of the services if provided separately (which in turn depends on the prices and specific services offered by different providers). C. Additional Fees Clients who participate in the wrap fee program will not have to pay for transaction or trading fees. However, clients are still responsible for all other account fees, such as certain charges imposed by custodians, brokers, and other third parties such as custodial fees, annual IRA fees, transition fees if the account is moved to another broker, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Also, clients will pay the following separately incurred expenses: charges imposed directly by a mutual fund, index fund, or exchange traded fund Wrap Fee Program Brochure Page 5 of 17 You may obtain a current copy of the Form CRS and our Form ADV Part 2 brochure at http://www.orgpag.com. which shall be disclosed in the fund's prospectus (i.e., fund management fees and other fund expenses). Clients may be responsible for paying fees charged by sub-advisers, money managers, platforms, and/or platform managers that have been engaged to manage their account as described in the investment management agreement. Such charges, fees, and commissions are exclusive of, and in addition to, our fee. Ascentis Wealth, our affiliate, receives a portion of fees charged by Platforms. D. Compensation of Client Participation Ascentis Wealth does not receive any additional compensation beyond advisory fees for the participation of clients in the wrap fee program. However, compensation received may be more than what would have been received if client paid separately for investment advice, brokerage, and other services. Therefore, Ascentis Wealth may have a financial incentive to recommend the wrap fee program to clients. Some affiliates of Ascentis Wealth are also associated with Ascentis Wealth in the capacity of investment advisor representative. Ascentis Wealth does receive fees beyond participation in a Wrap Fee Program. Ascentis Wealth receives a portion of the platform fee paid for clients on the platform. Account Requirements and Types of Clients Item 5 Ascentis Wealth generally provides its wrap fee program services to the following types of clients: Individuals • • High-Net-Worth Individuals • Pension and Profit-Sharing Plans • Trusts, Estates, or Charitable Organizations Ascentis Wealth does not impose an account minimum Performance-Based Fees and Side-By-Side Management Item 6 A. Selecting/Reviewing Portfolio Managers Ascentis Wealth is the only manager and sponsor in its wrap fee program. Accounts in the wrap fee program are managed by the Advisor. Ascentis Wealth may select outside portfolio managers for management of this wrap fee program by hiring sub-advisers. Ascentis Wealth has the ability to hire and fire any sub-advisers. As part of Ascentis Wealth’s asset management services, Ascentis Wealth will often invest your assets or recommend the investment of your assets according to one or more model portfolios developed by Ascentis Asset Management. In some cases, Ascentis Wealth may deviate or recommend a deviation from the Ascentis Asset Management models depending on individual client circumstances. With respect to discretionary accounts, Ascentis Wealth will monitor your portfolio's performance on an ongoing basis and attempt to rebalance the portfolio as required by changes in market conditions and in your financial circumstances. Standards Used to Calculate Portfolio Manager Performance: Ascentis Wealth reviews the performance information to determine and verify its accuracy and compliance with industry standards. The performance information is reviewed quarterly and is reviewed by Ascentis Wealth. B. Related Persons Ascentis Wealth and its personnel serve as the portfolio managers for all wrap fee program accounts. This is a conflict of interest in that no outside adviser assesses Ascentis Wealth’s management of the wrap fee program. However, Ascentis Wealth addresses this conflict by acting in its clients’ best interest consistent with its fiduciary duty as sponsor and portfolio manager of the wrap fee program. Ascentis Wealth may hire sub-advisers for portfolio management services. Ascentis Wealth has engaged Ascentis Asset Management, LLC as the sub- adviser for certain accounts. Ascentis Asset Managements receives a management fee as a result of the sub-advisory services provided to clients. This fee may be paid for by the client as outlined in the investment advisory agreement. Ascentis Wealth only recommends Ascentis Asset Wrap Fee Program Brochure Page 6 of 17 You may obtain a current copy of the Form CRS and our Form ADV Part 2 brochure at http://www.orgpag.com. Management to clients when Ascentis Wealth believes it is in the best interest of the client. Additionally, as of the date of this Brochure, Ascentis Asset Management does not receive a management or sub advisory fee with respect to the sub advisory services it provides to Ascentis Wealth. You are not obligated, contractually or otherwise, to utilize any Ascentis Asset Management service or invest in any Ascentis Asset Management product. C. Advisory Business Ascentis Wealth offers portfolio management services to its wrap fee program participants as discussed in Section 4 above. Wrap Fee Portfolio Management: Ascentis Wealth offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Ascentis Wealth advisors collect information from each client regarding their investment objectives, goals, and guidelines and then construct a plan to aid in the selection of a portfolio that matches each client’s specific situation. Ascentis Wealth manages the client’s assets with the goal of meeting the objectives set by the client. Portfolio management accounts participating in the wrap fee program will not have to pay for transaction or trading fees. Ascentis Wealth will charge clients one fee and pay transaction fees using the advisory fee collected from the client. However, clients are still responsible for all other account fees, such as certain charges imposed by custodians, brokers, and other third parties such as custodial fees, annual IRA fees, transition fees if the account is moved to another broker, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Also, clients will pay the following separately incurred expenses: charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund's prospectus (i.e., fund management fees and other fund expenses). Clients may be responsible for paying fees charged by sub- advisers, money managers, platforms, and/or platform managers that have been engaged to manage their account as described in the investment management agreement. Such charges, fees, and commissions are exclusive of, and in addition to, our fee. Ascentis Wealth, our affiliate, receives a portion of fees charged by Platforms. Accounts participating in the wrap fee program are not charged higher advisory fees based on trading activity, but clients should be aware that Ascentis Wealth has an incentive to limit trading activities for those accounts since the firm absorbs those transaction costs. To address this conflict, Ascentis Wealth will always act in the best interests of its clients consistent with its fiduciary duty as an investment adviser. Performance-Based Fees and Side-By-Side Management: Ascentis Wealth does not accept performance-based fees or other fees based on a share of capital gains or capital appreciation of the assets of a client. Services Limited to Specific Types of Investments: We primarily offer advice on a variety of investment options including mutual funds, exchange traded funds, and other securities, we may also recommend private equity funds or private placements securities, and may utilize sub-advisers, however we do not limit our advice to any particular investment strategies or securities. You may request that we refrain from investing in particular securities or certain types of securities. You must provide these restrictions to our firm in writing. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account. Client Tailored Services and Client Imposed Restrictions: Wrap Fee Program Brochure Page 7 of 17 You may obtain a current copy of the Form CRS and our Form ADV Part 2 brochure at http://www.orgpag.com. Ascentis Wealth offers the same suite of services to all of its clients. However, specific client financial plans and their implementation are dependent upon each client’s current situation (income, tax levels, and risk tolerance levels). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent Ascentis Wealth from properly servicing the client account, or if the restrictions would require Ascentis Wealth to deviate from its standard suite of services, Ascentis Wealth reserves the right to end the relationship. Wrap Fee Programs: Ascentis Wealth is the only manager and sponsor in its wrap fee program. Accounts in the wrap fee program are managed by Ascentis Wealth’s portfolio management team. These individuals also manage other accounts of Ascentis Wealth. Ascentis Wealth may select outside portfolio managers for management of this wrap fee program by hiring sub-advisers. Ascentis Wealth has the ability to hire and fire any sub-advisers. Ascentis Wealth has engaged Ascentis Asset Management the sub-adviser for wrap fee program accounts. Some accounts may be managed differently than non-wrap fee accounts. The fees paid to the wrap account program will be given to Ascentis Wealth and/or sub-advisers as a management fee depending on the client’s investment management agreement. Methods of Analysis and Investment Strategies: This section provides an overview of methods of analysis and investment strategies we may utilize in providing services to you and certain material risks relating that you may face in connection with these services. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. It is not possible to identify all of the risks associated with investing, and this section does not attempt to discuss all the risk that may affect your investments with Ascentis Wealth. Rather, this section discusses certain material risks of Ascentis Wealth’s investment activities. Different risks will impact different investment strategies to different degrees, and the degree to which a particular risk is applicable to you will depend on a variety of factors, including which investment strategy(ies) are employed with respect to your account and your investment guidelines. We do not guarantee that an investment objective or planning goal will be achieved or that any of the investment strategies will create their intended results. As an investor, each client must be able to bear the risk of loss that is associated with their account, which may include the loss of some, or all principal invested. No single investment strategy, or combination thereof, is necessarily diversified or intended to provide a complete investment program. Clients are responsible for appropriately diversifying their assets to guard against the risk of loss. You are responsible for your overall financial situation, and we urge you to consult legal, tax and other financial advisors regarding your specific or overall financial situation as needed. In particular, our strategies and investments may have unique and significant tax implications. We will generally attempt to structure your portfolio in the most tax efficient manner possible based on your accounts under our management. However, unless we specifically agree otherwise, and in writing, tax efficiency is not our primary consideration in the management of your assets. Regardless of your account size or any other factors, we strongly recommend that you continuously consult with a tax professional prior to and throughout the investing of your assets. Our investment strategies and advice may vary depending upon each client’s specific financial situation. As such, we determine investments and allocations based upon your predefined objectives, risk tolerance, time horizon, financial horizon, financial information, liquidity needs, and other various suitability factors. Your restrictions and guidelines may affect the composition and performance of your portfolio. We may use one or more of the following methods of analysis or investment strategies when providing Wrap Fee Program Brochure Page 8 of 17 You may obtain a current copy of the Form CRS and our Form ADV Part 2 brochure at http://www.orgpag.com. investment advice to you: Fundamental analysis is a method of evaluating a company that has issued a security by attempting to measure the value of its underlying assets. It entails studying overall economic and industry conditions, as well as the financial condition and the quality of the company’s management. Ascentis Wealth considers earnings, expenses, assets, and liabilities important in determining the value of a company. We then compare the value of the company to the current price of the issuing company's security to determine whether to purchase, sell or hold the security. One of the primary risks of fundamental analysis is that information obtained may be incorrect and the analysis may not provide an accurate estimate of earnings, which may be the basis for Ascentis Wealth’s valuation of a security. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Cyclical analysis is a form of fundamental analysis that involves the process of making investment decisions based on the different stages of an industry at a given point in time. One of the primary risks of cyclical analysis is the lengths of economic cycles may be difficult to predict with accuracy, which leads to difficulty in predicting economic trends and consequently the changing value of securities that would be affected by these changing trends. Quantitative Analysis is a method of determining the value of a security by examining its numerical, measurable characteristics such as revenues, earnings, margins, and market share. One of the primary risks of quantitative analysis is that empirical data may not necessarily be the best indicator of the value of certain investments, and purely mathematical approaches may not reveal significant security specific developments. Charting involves identifying patterns that can suggest future activity in price movements. A chart pattern is a distinct formation on a stock chart that creates a trading signal or a sign of future price movements. Chartists use these patterns to identify current trends and trend reversals to trigger buy and sell signals. Some of the chart types that Ascentis Wealth utilizes are Line Charts, Bar Charts, Candlestick, Point and Figure, etc. One of the primary risks of charting analysis is that it may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Technical analysis is a method of evaluating securities by analyzing statistics generated by market activity, such as past prices and volume. Technical analysts do not attempt to measure a security's intrinsic value, but instead use charts and other tools to identify patterns that can suggest future activity. One of the primary risks of market timing based on technical analysis is that our analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Long-Term Purchases – securities purchased with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which Wrap Fee Program Brochure Page 9 of 17 You may obtain a current copy of the Form CRS and our Form ADV Part 2 brochure at http://www.orgpag.com. may not be the case. There is also the risk that the segment of the market that you are invested in or perhaps just your particular investment will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - “locking-up” assets that may be better utilized in the short-term in other investments. Short-Term Purchases – securities purchased with the expectation that they will be sold within a relatively short period of time, generally less than one year, to take advantage of short-term price fluctuations. Using a short-term purchase strategy generally assumes that one can predict how financial markets will perform in the short-term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. There are many factors that can affect financial market performance in the short term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a smaller impact over longer periods of times. Short Sales – securities transactions in which securities are sold that were borrowed in anticipation of a price decline. The seller is then required to return an equal number of shares at some point in the future. The primary risk of short selling is that client assets invested through a short sale will profit if the stock goes down in price, but if the price of the shares increase, the potential losses are unlimited. We may use short-term trading (in general, selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Short-term trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and tolerance for risk. This may include buying and selling securities frequently in an effort to capture significant market gains and avoid significant losses. However, there is a risk that frequent trading can negatively affect investment performance, particularly through increased brokerage and other transactional costs and taxes. Margin Transactions – a securities transaction in which an investor borrows money to purchase a security, in which case the security serves as collateral on the loan. The primary risk of trading on margin is that if the value of the shares drops sufficiently, the client will be required to either deposit more cash into the account or sell a portion of the stock in order to maintain the margin requirements of the account. This is known as a "margin call." This could result in a client account losing more money than was invested in the margin transaction. Options Trading - a securities transaction that involves buying or selling (writing) an option. If you write an option, and the buyer exercises the option, you are obligated to purchase or deliver a specified number of shares at a specified price at the expiration of the option regardless of the market value of the security at expiration of the option. Buying an option gives you the right to purchase or sell a specified number of shares at a specified price until the date of expiration of the option regardless of the market value of the security at expiration of the option. Trading of options may be highly speculative and may entail more risk than those present when investing in other types of securities. Prices of options are generally more volatile than prices of other types of securities. When trading in options, you may run the risk of losing the entire investment in a relatively short period of time. In more risky options strategies, an investor could theoretically have an unlimited risk of loss. Management Risk: Judgements about the value and potential appreciation of a particular security may be wrong and there is no guarantee that securities will perform as anticipated. The value of a security can be more volatile than the market as a whole or our approach may fail to produce the intended results, which can result in losses for a client. Market Risk: There is a possibility that the value of securities may decline due to daily fluctuations in the markets. Stock prices change daily as a result of many factors, including developments affecting the condition of both individual companies and the market in general. In a declining stock market, prices for all companies Wrap Fee Program Brochure Page 10 of 17 You may obtain a current copy of the Form CRS and our Form ADV Part 2 brochure at http://www.orgpag.com. may decline regardless of their long-term prospects. Business, Terrorism and Catastrophe Risks: Investments are subject to the risk of loss arising from the occurrence of various events, including hurricanes, earthquakes, and other natural disasters, terrorism, and other catastrophic events such as a pandemic. These catastrophic risks of loss can be substantial and could have a material adverse effect on our business and clients’ portfolios. Risk of Loss: Investing in securities involves a risk of loss that you should be prepared to bear. We do not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. We cannot offer any guarantees or promises that your financial goals and objectives will be met. Past performance is in no way an indication of future performance. Recommendation of Particular Types of Securities: Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus investors may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. Mutual funds are also subject to extensive regulatory regimes, which may restrict their investments and result in lower investment returns than less-regulated investments. Equity: investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed Income Securities: Investments in fixed income securities are subject to credit, liquidity, prepayment, and interest rate risks, any of which may adversely impact the price of the security and result in a loss. The municipal market can be significantly affected by adverse tax, legislative or political changes and the financial condition of the issuers of municipal securities. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks, and their price can fluctuate during the day. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically maybe negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. The returns on ETFs can be reduced by the costs of managing the funds. During a time of extreme market volatility ETF pricing may lag vs. the actual underlying asset values. This lag usually resolves itself in a short period of time (usually less than one day) however there is no guarantee this relationship will always occur. In addition, for certain ETFs recommended by us, there may be little public market due to trading volumes or other factors. Accordingly, clients may not be able to sell the ETFs as desired. Real estate: funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit Wrap Fee Program Brochure Page 11 of 17 You may obtain a current copy of the Form CRS and our Form ADV Part 2 brochure at http://www.orgpag.com. markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Private Equity (PE) Funds and Private placement Securities Risks are inherently illiquid; they cannot be easily sold or exchanged for cash without a substantial loss in value. Investors are usually required to commit their capital for extended periods. Private equity funds typically charge high fees, including management fees and performance fees (carried interest). These fees can erode returns, especially if the fund's performance does not meet expectations. Private Equity funds are subject to higher degrees of risk and may not be suitable for all investors. Their performance is heavily dependent on the skill and experience of the management team. Private equity funds commonly use leverage (borrowed funds) to enhance returns, which can increase the potential for significant losses, especially in downturns. In addition, Private Equity investments often lack transparency. Detailed information about the fund's operations and investments is not readily available, making it challenging to evaluate the valuations of private companies. Private Placement Securities have similar characteristics and carry risks akin to those of Private Equity Funds. However, Private Placements are typically offered to institutional clients or accredited investors. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you should be prepared to bear. Voting Client Proxies: Asecntis Wealth does not and will not accept the proxy authority to vote client securities. Clients will receive proxies or other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent to Ascentis Wealth’s office, Ascentis Wealth will forward them to the client and ask the party who sent them to mail them directly to the client in the future. Clients may call, write, or email Ascentis Wealth to discuss questions they may have about particular proxy votes or other solicitations. Client Information Provided to Portfolio Managers Item 7 Ascentis Wealth gathers information such as guidelines, restrictions, and suitability as part of the account opening process. This information (including basic information, risk tolerance, sophistication level, and income level) is provided to the portfolio manager. The portfolio manager will also have access to that information as it changes and is updated. Client Contact with Portfolio Manager Item 8 Ascentis Wealth places no restrictions on a client’s ability to contact its portfolio managers. Clients may contact Ascentis Wealth to arrange for a consultation regarding the management of their account. Ascentis Wealth portfolio managers are available at reasonable times to participate in consultations that clients request. Additional Information Item 9 A. Disciplinary Action and Other Financial Industry Activities Criminal or Civil Actions: There are no criminal or civil actions to report. Administrative Proceedings: There are no administrative proceedings to report. Wrap Fee Program Brochure Page 12 of 17 You may obtain a current copy of the Form CRS and our Form ADV Part 2 brochure at http://www.orgpag.com. Self-regulatory Organization Proceedings: There are no self-regulatory organization proceedings to report. Registration as a Broker/Dealer or Broker/Dealer Representative: Some supervised persons of our firm are registered representatives of a broker dealer. These supervised persons offer securities and receive normal and customary commissions as a result of securities transactions. However, supervised persons do not receive any commissions as a result of securities transactions for Ascentis Wealth client accounts. Registration as a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor Neither Ascentis Wealth nor its representatives are registered as or have pending applications to become a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests through common ownership. Ascentis Wealth has an affiliation with Ascentis Asset Management, an investment advisory firm that is registered with the SEC. Ascentis Asset Management primarily provides outsourced chief investment services to other investment advisers. Supervised persons of Ascentis Wealth are supervised persons of Ascentis Asset Management and will offer clients advice or products from those activities and clients should be aware that these services involve a conflict of interest. Supervised persons must determine the amount of time to dedicate to Ascentis Wealth and Ascentis Asset Management. We have engaged Ascentis Asset Management as the sub-adviser for client accounts. This creates a conflict of interest because we have an incentive to recommend Ascentis Asset Management as the sub-adviser for client accounts. We only recommend Ascentis Asset Management to clients when we believe it is in the best interest of the client. Additionally, as of the date of this Brochure, Ascentis Asset Management does not receive a management or sub advisory fee with respect to the sub advisory services it provides to Ascentis Wealth. You are not obligated, contractually or otherwise, to utilize any Ascentis Asset Management service or invest in any Ascentis Asset Management product. We do not receive client referrals from broker-dealers in exchange for cash or other compensation, such as brokerage services or research. Our affiliate, Ascentis Asset Management, does have a fee sharing agreement with SMH that allows that entity to receive a share of the revenue that SMH earns from margin loan spreads and remarketing fees from money market-sweep products generated by clients referred to SMH. Although Ascentis does not receive compensation directly, this fee sharing agreement does benefit our affiliate and as such creates a conflict when we refer to clients to SMH. Client accounts are generally managed via third-party investment management platforms (“Platforms”). Platforms are paid a fee based on the amount of client assets on the Platform (“Platform Fee”). Ascentis Wealth, or our affiliates, receives a portion of the Platform Fee. The Platform Fee is higher as a result of our receipt of a portion of the Platform Fee and clients may be able to access Platforms through other investment advisers at a lower fee. Clients may be responsible for paying the Platform Fee as described in the investment management agreement. Clients should review the investment management agreement to determine if they are responsible for paying the Platform Fee. This fee is in addition to the compensation we receive for our advisory services described in Item 5. Fees reduce returns over time. This creates a conflict of interest as we have an incentive to recommend Platforms based on our receipt of a portion of the Platform Fee rather than the best interests of the client. We have reviewed and periodically review Platforms that we recommend and believe that the use of such Platforms is in the best interest of clients. As of the date of this Brochure, we utilize Envestnet as a Platform. Wrap Fee Program Brochure Page 13 of 17 You may obtain a current copy of the Form CRS and our Form ADV Part 2 brochure at http://www.orgpag.com. Insurance Agent: Some Representatives of our firm are insurance agents/brokers. A conflict of interest arises as these insurance sales create an incentive to recommend products based on the compensation our supervised persons earn. You are not obligated, contractually or otherwise, to purchase insurance from any representative of Ascentis Wealth. Selection of Other Advisors or Managers and How This Adviser is Compensated for Those Selections. Some supervised persons of our firm recommend other investment advisers for clients and receive compensation from those advisers for the recommendation. This creates a conflict of interest as the supervised person has an incentive to recommend the investment adviser based on compensation received rather than the best interests of the client. All supervised persons receive training regarding, among other things, their fiduciary duty to clients and obligation to make recommendations taking into account only the client’s best interest. Supervised persons are also required to deliver a disclosure document to the client containing the following information: the supervised person’s and recommended investment adviser’s names; the nature of the relationship between the supervised person and the recommended investment adviser, including any affiliation; a statement that the supervised person is compensated by the recommended investment adviser and the terms and description of compensation; and the amount, if any, which will be charged to the client in addition to the advisory fee, as well as other fee information, if applicable. In addition, we may recommend other investment advisers for clients through the selection of sub-advisers, mutual funds, ETFs, and separate account strategies. We do not generally receive compensation related to these recommendations with the exception of Model ETFs and Model Products, as described above. B. Code of Ethics, Client Referrals, and Financial Information Code of Ethics We have adopted a Code of Ethics pursuant to Advisers Act Rule 204A-1. A basic tenet of our Code of Ethics is that the interests of clients are always placed first. The Code of Ethics includes standards of business conduct requiring Access Persons to comply with the federal securities laws and the fiduciary duties an investment adviser owes to its clients. The Code of Ethics also requires that all Access Persons comply with ethical restraints relating to clients and their accounts, including restrictions on gifts and provisions intended to prevent violations of laws prohibiting insider trading. The goal of our Code of Ethics is to ensure personal investing activities by our employees are consistent with our fiduciary duty to our clients. The Code of Ethics includes standards of business conduct requiring Access Persons to comply with the federal securities laws and the fiduciary duties an investment adviser owes to its clients. For purposes of the Code of Ethics, we have determined that all employees are Access Persons. In order to avoid potential conflicts of interest that could be created by personal trading among our Access Persons, the Code of Ethics restricts the purchase and sale by Access Persons for their own accounts of any covered security before the execution of a transaction in any such security for clients. All Access Persons are required to notify our Chief Compliance Officer or his designee of their personal transactions. All Access Persons are required to submit quarterly personal securities transactions and annual holdings reports for review by the Chief Compliance Officer, or designee. Access Persons are also required to have copies of all brokerage statements sent to the Chief Compliance Officer, directly from the custodian(s), on, at least, a quarterly basis. The Chief Compliance Officer will maintain documentation of personal securities transactions, including any violations that occur and their resulting actions. The Code of Ethics also requires that all Access Persons comply with ethical restraints relating to clients and their accounts, including restrictions on gifts and provisions intended to prevent violations of laws prohibiting insider trading. Wrap Fee Program Brochure Page 14 of 17 You may obtain a current copy of the Form CRS and our Form ADV Part 2 brochure at http://www.orgpag.com. Our Code of Ethics is available to you upon request. You may obtain a copy of our Code of Ethics by contacting us at the number on the cover page of this Brochure. As a matter of policy, we do not engage in principal transactions, cross trading, or agency cross transactions. Any exceptions to this policy must be approved in advance by the Chief Compliance Officer or by his designee. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews: IARs are required to conduct quarterly reviews of client statements to ensure 1) the statement is alignment with the Investor Advisory Agreement and agreed contractual fee schedule, 2) the clients’ accounts are in line with their investment objectives, appropriately positioned based on market conditions, and investment policies, if applicable. On an annual basis, Ascentis Wealth monitors client accounts to ensure IARs are adhering to the requirements noted above. Ascentis Wealth does not provide written reports to clients, however, IARs may create consolidated-performance statements. It is important to note the custodian’s statements supersede any reports generated by your IAR. Factors That Will Trigger a Non-Periodic Review of Client Accounts: We monitor Asset Management accounts on an ongoing basis and conduct an internal review account on at as part of the firm 206-4 inspection. The nature of our internal reviews is to learn whether clients’ accounts are in line with their investment objectives, appropriately positioned based on market conditions, and investment policies, if applicable. We do not provide written reports to clients, unless asked to do so. Verbal reports to clients take place on at least an annual basis when we contact clients who subscribe to our Asset Management services. We may review client accounts more frequently than described above. Among the factors which may trigger an off-cycle review are major market or economic events, the client’s life events, requests by the client, etc. Financial Planning clients do not receive reviews of their written plans unless they take action to schedule a financial consultation with us. We do not provide ongoing services to financial planning clients, but are willing to meet with such clients upon their request to discuss updates to their plans, changes in their circumstances, etc. Financial Planning clients do not receive written or verbal updated reports regarding their financial plans unless they separately contract with us for a post-financial plan meeting or update to their initial written financial plan. Content and Frequency of Regular Reports Provided to Clients: Each client will receive, at least quarterly, from the custodian a written report that details the client’s account including assets held and asset value which will come from the custodian. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) Charles Schwab & Co., Inc.: Our firm recommends that clients establish brokerage accounts with the Schwab Advisor Services division of Charles Schwab & Co., Inc. (“Schwab”), a registered broker-dealer, member SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. The final decision to custody assets with Schwab is at the discretion of Ascentis Wealth’s clients, including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA accountholder. Ascentis Wealth is independently owned and operated and not affiliated with Schwab. Schwab provides Ascentis Wealth with access to its institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to advisors. Schwab’s services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or Wrap Fee Program Brochure Page 15 of 17 You may obtain a current copy of the Form CRS and our Form ADV Part 2 brochure at http://www.orgpag.com. would require a significantly higher minimum initial investment. Schwab has eliminated commissions for online trades of equities, ETFs, and options (subject to $.065 per contract fee). This means that, in most cases, when we buy and sell these types of securities, we will not have to pay any commissions to Schwab. We encourage you to review Schwab’s pricing to compare the total costs of entering a wrap fee arrangement versus a non- wrap fee arrangement. If you choose to enter into a wrap fee arrangement, your total cost to invest could exceed the cost of paying for brokerage and advisory services separately. To see what you would pay for transactions in a non- wrap account please refer to Schwab’s most recent pricing schedule available at schwab.com/aspricingguide. Schwab also makes available to Ascentis Wealth other products and services that benefit Ascentis Wealth but may not benefit its clients’ accounts. These benefits may include national, regional or Ascentis Wealth specific educational events organized and/or sponsored by Schwab Advisor Services. Other potential benefits may include occasional business entertainment of personnel of Ascentis Wealth by Schwab Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist Ascentis Wealth in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), provide research, pricing information and other market data, facilitate payment of Ascentis Wealth’s fees from its clients’ accounts, and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of Ascentis Wealth’s accounts, including accounts not maintained at Schwab Advisor Services. Schwab Advisor Services also makes available to Ascentis Wealth other services intended to help Ascentis Wealth manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance, and marketing. In addition, Schwab makes available, arranges and/or pays vendors for these types of services rendered to Ascentis Wealth by independent third parties. Schwab Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third- party providing these services to Ascentis Wealth. While, as a fiduciary, Ascentis Wealth endeavors to act in its clients’ best interests, Ascentis Wealth’s recommendation that clients maintain their assets in accounts at Schwab may be based in part on the benefit to Ascentis Wealth of the availability of some of the foregoing products and services and other arrangements and not solely on the nature, cost or quality of custody and brokerage services provided by Schwab, which creates a potential conflict of interest. Sanders Morris Harris: Our firm recommends that clients establish brokerage accounts with the Sanders Morris Harris, LLC (“SMH”), a registered broker-dealer, member SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. The final decision to custody assets with SMH is at the discretion of the client, including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA accountholder. Ascentis Wealth is independently owned and operated and not affiliated with SMH. SMH provides Ascentis Wealth with access to its institutional trading and custody services, which are typically not available to SMH retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to advisors. SMH’s services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and Wrap Fee Program Brochure Page 16 of 17 You may obtain a current copy of the Form CRS and our Form ADV Part 2 brochure at http://www.orgpag.com. reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. SMH also makes available to Ascentis Wealth other products and services that benefit Ascentis Wealth but may not benefit its clients’ accounts. These benefits may include national, regional or Ascentis Wealth specific educational events organized and/or sponsored by SMH Services. Other potential benefits may include occasional business entertainment of personnel of Ascentis Wealth by SMH Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Platforms: Client accounts are generally managed via third-party investment management platforms (“Platforms”). Platforms are paid a fee based on the amount of client assets on the Platform (“Platform Fee”). Ascentis Wealth, or our affiliates, receives a portion of the Platform Fee. The Platform Fee is higher as a result of our receipt of a portion of the Platform Fee and clients may be able to access Platforms through other investment advisers at a lower fee. Clients may be responsible for paying the Platform Fee as described in the investment management agreement. Clients should review the investment management agreement to determine if they are responsible for paying the Platform Fee. This fee is in addition to the compensation we receive for our advisory services described in Item 5. Fees reduce returns over time. This creates a conflict of interest as we have an incentive to recommend Platforms based on our receipt of a portion of the Platform Fee rather than the best interests of the client. We have reviewed and periodically review Platforms that we recommend and believe that the use of such Platforms is in the best interest of clients. As of the date of this Brochure, we utilize Envestnet as a Platform. Compensation to Non – Advisory Personnel for Client Referrals: Ascentis Wealth has entered into an arrangement with Ascentis Asset Management where Ascentis Wealth refers prospective investment adviser representatives to Ascentis Asset Management and Ascentis Asset Management pays Ascentis Wealth a referral fee. The referral fee is equal to a percentage of the asset management fees received from Ascentis Asset Management clients serviced by investment adviser representatives referred by Ascentis Wealth, minus certain expenses that Ascentis Wealth has agreed to share with Ascentis Asset Management. The referral fee paid to Ascentis Wealth does not result in any increase in the advisory fee paid by clients. Balance Sheet: Ascentis Wealth does not require nor solicit prepayment of more than $1,200 in fees per client, six months or more in advance and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Ascentis Wealth nor its management have any financial conditions that are likely to reasonably impair our ability to meet contractual commitments to clients. Bankruptcy Petitions in Previous Ten Years: Ascentis Wealth has not been the subject of a bankruptcy petition in the last ten years. Wrap Fee Program Brochure Page 17 of 17 You may obtain a current copy of the Form CRS and our Form ADV Part 2 brochure at http://www.orgpag.com.