PACIFIC CAPITAL

Item 1 – Cover Page Pacific Capital Wealth Advisors, Inc. 1861 California Avenue, Suite 101 Corona, CA 92881 (844) 777-8777 www.pacificcapital.com Form ADV Part 2A Firm Brochure December 19, 2025 Pacific Capital Wealth Advisors, Inc. (“Pacific Capital”) is a registered investment adviser. An "investment adviser" means any person who, for compensation, engages in the business of advising others, either directly or through publications or writings, as to the value of securities or as to the advisability of investing in, purchasing, or selling securities, or who, for compensation and as part of a regular business, issues or promulgates analyses or reports concerning securities. Registration with the SEC or any state securities authority does not imply a certain level of skill or training. This brochure provides information about the qualifications and business practices of Pacific Capital. If you have any questions about the contents of this brochure, please contact us at (844) 777-8777. 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 Pacific Capital is available on the SEC’s website at www.adviserinfo.sec.gov. The firm's CRD/IARD number is 159294.  Pacific Capital Wealth Advisors, Inc. Form ADV Part 2A Brochure Page 2 Item 2 – Material Changes The purpose of this page is to inform you of any material changes since the previous required annual updating filing of this brochure. Since the last annual filing of this brochure with securities regulators on March 11, 2025, we have substantially rewritten our entire brochure for clarity. We have not changed the way we service your accounts, but we encourage you to review the information in this brochure. If you have questions or if you would like to receive a complete copy of our current brochure free of charge at any time, please contact us at (844) 777-8777 or at aurielle@pacificcapital.com. Additionally, you can find a copy of our most recent brochure online at https://adviserinfo.sec.gov/firm/summary/159294 or on our website at www.pacificcapital.com.  Pacific Capital Wealth Advisors, Inc. Form ADV Part 2A Brochure Page 3 Item 3 – Table of Contents Item 1 – Cover Page .................................................................................................................................. 1 Item 2 – Material Changes ........................................................................................................................ 2 Item 3 – Table of Contents ........................................................................................................................ 3 Item 4 – Advisory Business ....................................................................................................................... 4 Item 5 – Fees and Compensation ............................................................................................................. 7 Item 6 – Performance-Based Fees and Side-By-Side Management ....................................................... 10 Item 7 – Types of Clients ......................................................................................................................... 11 Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss ................................................. 11 Item 9 – Disciplinary Information ........................................................................................................... 17 Item 10 – Other Financial Industry Activities or Affiliations ................................................................... 17 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .......... 18 Item 12 – Brokerage Practices ................................................................................................................ 19 Item 13 – Review of Accounts ................................................................................................................ 22 Item 14 – Client Referrals and Other Compensation .............................................................................. 23 Item 15 – Custody ................................................................................................................................... 23 Item 16 – Investment Discretion ............................................................................................................ 24 Item 17 – Voting Client Securities ........................................................................................................... 24 Item 18 – Financial Information .............................................................................................................. 24  Pacific Capital Wealth Advisors, Inc. Form ADV Part 2A Brochure Page 4 Item 4 – Advisory Business Pacific Capital Wealth Advisors, Inc. (hereinafter “Pacific Capital”) is a registered investment advisor based in Corona, California. We are a corporation formed under the laws of the state of California. We have been providing investment advisory services since 2011. Chad T. Willardson is the sole owner and President of Pacific Capital. Aurielle West is our Chief Compliance Officer. You may see the term Associated Person throughout this Brochure. As used in this Brochure, this term refers to individuals associated with Pacific Capital, including officers, employees, and individuals providing investment advice on behalf of our firm. Where required, such persons are properly registered as investment adviser representatives. We believe that disciplined asset management and portfolio analysis are critical in order to achieve our clients' desired goals and objectives. Currently, we offer the following investment advisory services, personalized for each client: Financial Planning Services We offer financial planning services, which we refer to as our Financial Life Inspection®. The Financial Life Inspection® covers 100 checkpoints, including but not limited to (as applicable based on the client’s specific circumstances), comprehensive savings and retirement planning, income analysis, a full portfolio investment review, risk analysis, a college planning report, a tax optimization review, real estate review, legacy planning and asset protection review, debt analysis, and access to a secure online document vault. We provide ongoing financial advice and guidance after delivering the Financial Life Inspection® to all clients who engage us for investment management services. Financial plans are based on your financial situation pursuant to the information you provide to us at the time you engage us for such services. Please notify us promptly if your goals or circumstances change. Important Note: Information related to tax and legal matters that is provided as part of a financial plan is for informative purposes only. Clients are instructed to contact their tax or legal advisers for personalized tax or legal advice. Investment Management Services We offer ongoing investment management services tailored to the client’s investment objectives and risk tolerance. Such information will be gathered through personal discussions to establish goals and objectives based on the client’s unique circumstances. Pacific Capital will manage the investments in client accounts on a discretionary basis, adhering to the objectives, limitations, and restrictions outlined in the Investment Strategy Guide set forth in the Investment Advisory Agreement. Discretionary management means we will make investment decisions and place buy or sell orders in your investment account without contacting you before each transaction. These decisions and transactions will be made based on your stated investment objectives. If you wish, you may limit our discretionary authority by, for example, setting a limit on the type of securities that can be purchased for your account. Simply provide us with your restrictions or guidelines in writing. Pacific Capital does not specialize in specific types of securities. We can advise clients on various types of securities, such as exchange listed equities, over the counter equities, foreign issues, American depository  Pacific Capital Wealth Advisors, Inc. Form ADV Part 2A Brochure Page 5 receipts, corporate debt securities, commercial paper, certificates of deposit, municipal securities, investment company securities (including mutual funds and exchange traded funds), US Government securities, options contracts on securities and/or commodities, private equity instruments, and interests in partnership investing in real estate. Additionally, we will provide advice on existing investments you may hold at the inception of the advisory relationship or on other types of investments for which you ask advice. If you engage us for investment management services, we will monitor your portfolio’s performance continuously and rebalance your account(s) whenever necessary, as changes occur in market conditions and/or your financial circumstances. Please notify us promptly if your goals or circumstances change. Recommendation of Other Investment Advisors When a prospective client is not a fit for Pacific Capital, we may recommend an unaffiliated, third-party investment adviser (TPIA). Unless otherwise exempted from registration, recommended TPIAs must be registered as investment advisers with either the Securities and Exchange Commission or with applicable state securities authorities. If the prospect engages a recommended TPIA with whom we have a referral fee arrangement, we will receive a referral fee, which may be a one-time fee or an ongoing fee based on a percentage of the fees the referred party pays to the TPIA. Our compensation arrangements may differ depending on our agreement with each recommended TPIA. Therefore, we have an incentive to recommend TPIAs with whom we have more favorable compensation arrangements. Prospects are not obligated to utilize any recommended TPIA. If we refer you to a TPIA, please carefully review the disclosure documents and advisory agreement of any recommended TPIA for additional information regarding the TPIA’s services and fees, including any additional or higher costs due to referral fee arrangements they may have with us. ERISA Plan Services Pacific Capital offers services to qualified retirement plans, including 401(k) plans, 403(b) plans, pension and profit- sharing plans, cash balance plans, and deferred compensation plans. Pacific Capital may act as a 3(21) advisor. Limited Scope ERISA 3(21) Fiduciary Pacific Capital may serve as a limited scope ERISA 3(21) fiduciary that can advise, help, and assist plan sponsors with their investment decisions. As an investment advisor, Pacific Capital has a fiduciary duty to act in the best interest of the Plan Sponsor. The Plan Sponsor retains ultimate responsibility for the decisions made within the plan, though engaging Pacific Capital can help the Plan Sponsor delegate liability by following a diligent process. 1. Fiduciary Services may include one or more of the following: • Providing investment advice to the Plan Sponsor about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. The Plan Sponsor will make the final decision regarding the initial selection, retention, removal, and addition of investment options. Pacific Capital acknowledges that it is a fiduciary as defined in ERISA Section 3(21)(A)(ii). • Assisting the Plan Sponsor in the development of an Investment Strategy Guide (“ISG”), which • establishes the investment policies and objectives for the Plan. The Plan Sponsor retains ultimate responsibility and authority to establish such policies and objectives and to adopt or amend the ISG. Providing investment advice to the Plan Sponsor regarding the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Plan Sponsor retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c)(5) and 404(a)-5.  Pacific Capital Wealth Advisors, Inc. Form ADV Part 2A Brochure Page 6 • Assisting in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management, and adherence to the guidelines outlined in the ISG, along with recommendations for maintaining, removing, or replacing investment options. • Meeting with the Plan Sponsor periodically to discuss the reports and the investment recommendations. 2. Non-fiduciary Services may include one or more of the following: • Assisting in the education of Plan participants by providing general investment information and the investment alternatives available to them under the Plan. The Plan Sponsor understands that Pacific Capital’s assistance in the education of the Plan participants will align with the Department of Labor’s definition of investment education, as outlined in Interpretive Bulletin 96-1. As such, Pacific Capital is not providing fiduciary advice to Plan participants as defined by ERISA 3(21)(A)(ii). Pacific Capital will not provide advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan. • Assisting in group enrollment meetings designed to increase employee participation in the retirement plan and enhance their understanding of investments and financial concepts. Pacific Capital may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between Pacific Capital and the Plan Sponsor. 3. Pacific Capital has no responsibility to provide services related to the following types of assets (“Excluded Employer securities; Stock brokerage accounts or mutual fund windows; Participant loans; Assets”): • • Real estate (except for real estate funds or publicly traded REITs); • • • Non-publicly traded partnership interests; • Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or • Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in the calculation of costs paid to Pacific Capital on the ERISA Agreement. Specific services will be outlined in detail in each plan in the 408(b)2 disclosure. Other ERISA Plan Services may be negotiated. All such services, whether general or customized, will be outlined in the ERISA Plan Agreement that shows the services to be provided and the fees to be charged. Pacific Capital is registered as an investment advisor and represents that it is not subject to any disqualification as set forth in Section 411 of ERISA. To the extent Pacific Capital performs Fiduciary Services, Pacific Capital is acting as a fiduciary of the Plan as defined in Section 3(21) under ERISA. Wrap Fee Programs We do not sponsor, manage, or participate in any wrap fee programs. Assets Under Management As of September 30, 2025, we had approximately $654,689,148 in discretionary assets under management. We do not manage assets on a non-discretionary basis.  Pacific Capital Wealth Advisors, Inc. Form ADV Part 2A Brochure Page 7 Item 5 – Fees and Compensation Financial Planning Fees The Financial Life Inspection® is offered for a flat cost of $ $9,600.00. The fee is negotiable at our discretion, depending on the client’s specific needs and circumstances. The fee for the Financial Life Inspection® is due upon signing the Agreement. The Financial Life Inspection® will be completed within two (2) weeks, or no greater than 90 days, of receiving all necessary information and payment from the client. Clients may cancel within five (5) business days of signing the Agreement for a full refund and with no obligation. If the client cancels after the initial five (5) business days, they may cancel by providing written notice to us, and will be provided a pro-rata refund based on the percentage of work completed. If the client and Pacific Capital agree to investment management services, the client will continue to receive ongoing financial advice and guidance as needed. Investment Management Fees The annual fee for our investment management services is calculated as a percentage of the assets under our supervision and management. The annual fee is billed quarterly in advance based on the market value reported by the account custodian as of the last business day of the previous calendar quarter, in accordance with the following fee schedule. ASSET VALUE $0 to $24,999,999 $25,000,000 to $49,999,999 $50,000,000 to $99,999,999 Above $100,000,000 ANNUAL FEE 1.25% 1.125% 1.00% Customized/Negotiable For example, the quarterly fee for an account valued at $20,0000 would be calculated using the following formula: ($20,000)(.0125) / 365 = X (# the number of days in that quarter). In certain circumstances and at our sole discretion, fees and account minimums may be negotiable based upon prior relationships as well as related account holdings. Additionally, at our discretion, we generally aggregate related client accounts for purposes of calculating the fee applicable to each client. We also reserve the right to reduce or waive fees for employee or family accounts and certain client accounts. The exact fee schedule for supervisory and management services and payment arrangements will be set forth in the written agreement between the client and Pacific Capital. We will deduct our fee directly from the client’s account(s) through the unaffiliated, qualified custodian holding the client’s funds and securities. Pacific Capital does not have access to client funds for payment of fees without client consent in writing. The client provides written authorization permitting the fees to be paid directly from the client’s account held by the account custodian. The custodian will send the client a statement, at least quarterly, indicating all amounts dispersed from the account, including the amount of the advisory fee paid directly to Pacific Capital. Pacific Capital will also receive a copy of your account statements from the custodian. Please review each statement for accuracy. Please let us know immediately if you have questions about it or if you did not receive a statement.  Pacific Capital Wealth Advisors, Inc. Form ADV Part 2A Brochure Page 8 Deposits made to an account(s) during the quarter, after billing has been completed, will be billed at the start of the next quarter, in arrears. The adjusted fee will be prorated by the number of days the assets were being managed for that quarter and added to the applicable billing amount for the following quarter. Withdrawals are subject to standard securities settlement periods, and the creation of cash may take a few business days. The client must promptly notify us of any contributions or withdrawals, as such changes may have an impact upon the management of the account(s), may have tax consequences, and may adversely affect the performance of the account. Although some of our clients choose to utilize margin loans from their custodian accounts, we do not recommend using margin for the purpose of increasing a client’s investment account values. Discussing debt and debt paydown plans is part of our financial planning process with clients. Clients with an account at a qualified custodian may have the option to borrow money from the custodian using their investment account as collateral. Should a client make a deposit into an existing account at the custodian that has a margin loan balance, we will confirm with the client whether they intend for those monies to be used to pay down the margin loan or to be invested. If margin is utilized, our fee will be billed based on the gross invested asset value of the account(s). At the inception of services, the first quarter’s fees will be prorated, if applicable, based on the number of days remaining in the first quarter. The Investment Advisory Agreement between the client and Pacific Capital will continue in effect until either party terminates the agreement in accordance with the terms of the agreement. Either party to the written agreement may terminate the agreement in accordance with the terms of the agreement. The fees will be prorated for the billing period in which the termination notice is given, and any prepaid, unearned fees will be promptly refunded to the client using the following formula: (Costs Paid) x (Days Remaining in Quarter) / (Total Number of Days in Quarter). ERISA Plan Fees The annual fee is negotiated independently with each Plan Sponsor, depending on the varying, unique characteristics or requirements of each plan. Primary determinants of the negotiated fee typically include, but are not limited to, the amount of plan assets, the number of employees/plan participants, the number of plan sponsor locations, and any special Plan Sponsor considerations or requirements. The maximum annual fee will not exceed 1.00% of the market value of the Included Plan Assets. Our fee will be due quarterly or monthly in arrears or in advance based on the assets as calculated by the custodian or record keeper of the Included Plan Assets (without adjustments for anticipated withdrawals by Plan participants or other anticipated or scheduled transfers or distribution of assets). The exact fee and fee payment arrangements will be clearly set forth in the ERISA Plan Agreement between the Plan Sponsor and Pacific Capital. If the services to be provided start any time other than the first day of a calendar quarter or month, the fee will be prorated based on the remaining days in that period. If the ERISA Plan Agreement is terminated before the end of the billing cycle, Pacific Capital shall be entitled to a prorated payment for the days services were provided, or we will issue a prorated refund for the days services were not provided in the billing cycle if fees were paid in advance. The fee schedule, which outlines Pacific Capital’s compensation for services, is detailed in the ERISA Plan Agreement. Generally, the Plan Sponsor may elect to be billed directly or have the costs deducted from plan assets. Pacific Capital does not reasonably expect to receive any additional compensation, directly or indirectly, for its services under the ERISA Plan Agreement. If any additional compensation is received, Pacific Capital will disclose this compensation, the services rendered, and the source of the  Pacific Capital Wealth Advisors, Inc. Form ADV Part 2A Brochure Page 9 compensation to the Plan Sponsor, and any such compensation will be offset against the fees as agreed upon under the ERISA Plan Agreement. Additional Fees and Expenses As described above, the fees are charged as described and are not based on a share of capital gains of the funds of any advisory client. Our annual fees are exclusive of, and in addition to, brokerage commissions, transaction fees, and other related costs and expenses. You are responsible for brokerage costs incurred. However, Pacific Capital will not receive any portion of the commissions, fees, and costs. The client may also incur charges for other account services provided by the custodian not directly related to the execution and clearing of transactions, including, but not limited to, interest charges on margin loans, and legal costs or costs for transfers of securities. Please see Item 12 – Brokerage Practices for further information on brokerage and transaction costs. All fees paid to Pacific Capital for investment advisory services are separate and distinct from the fees and expenses charged to shareholders by mutual funds or exchange traded funds. These fees and expenses are described in each fund's prospectus. These fees generally include a management fee, other fund expenses, and a possible distribution fee. If the fund also imposes sales charges, you may pay an initial or deferred sales charge. A client could invest in a mutual fund directly, without the services of Pacific Capital. In which case, the client would not receive the services provided by Pacific Capital, which are designed, among other things, to assist the client in determining which mutual fund or funds are most appropriate to their financial condition and objectives. Accordingly, clients should review the fees charged by the funds and the fees charged by Pacific Capital to fully understand the total amount of fees charged and to evaluate the cost of advisory services being provided. We do not represent, warrant, or imply that the services or methods of analysis employed by us can or will predict future results, successfully identify market tops or bottoms, or insulate you from losses due to market corrections or declines. Billing on Cash Positions The firm treats cash and cash equivalents as an asset class. Accordingly, unless otherwise agreed in writing, all cash and cash equivalent positions (e.g., money market funds, etc.) are included as part of assets under management for purposes of calculating the firm’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), the firm may maintain cash and/or cash equivalent positions for defensive, liquidity, or other purposes. While assets are maintained in cash or cash equivalents, such amounts could miss market advances and, depending upon current yields, at any point in time, the firm’s advisory fee could exceed the interest paid by the client’s cash or cash equivalent positions. Periods of Portfolio Inactivity The firm has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, the firm will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including but not limited to investment performance, fund manager tenure, style drift, account additions/withdrawals, the client’s financial circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may be extended periods of time  Pacific Capital Wealth Advisors, Inc. Form ADV Part 2A Brochure Page 10 when the firm determines that changes to a client’s portfolio are neither necessary nor prudent. Notwithstanding, unless otherwise agreed in writing, the firm’s annual investment advisory fee will continue to apply during these periods, and there can be no assurance that investment decisions made by the firm will be profitable or equal any specific performance level(s). IRA Rollover Considerations As a normal extension of financial advice, we offer education or recommendations related to the rollover of an employer-sponsored retirement plan. A plan participant leaving employment has several options. Each choice offers advantages and disadvantages, depending on desired investment options and services, fees and expenses, withdrawal options, required minimum distributions, tax treatment, and the investor's unique financial needs and retirement plans. The complexity of these choices may lead an investor to seek assistance from us. An Associated Person who recommends an investor roll over plan assets into an Individual Retirement Account (“IRA”) may earn an asset-based fee as a result, but no compensation if assets are retained in the plan. Thus, we have an economic incentive to encourage an investor to roll plan assets into an IRA. In most cases, fees and expenses will increase to the investor as a result because the above-described fees will apply to assets rolled over to an IRA, and the outlined ongoing services will be extended to these assets. We are fiduciaries under the Investment Advisers Act of 1940. We must act in your best interest and not put our interests ahead of yours. At the same time, the way we make money creates some inherent conflicts with clients’ interests. You are under no obligation to roll over plan assets to an IRA under our management. Compensation for the Sale of Insurance Products Certain Executive Officers and other Associated Persons of our firm are licensed as independent insurance agents. Insurance products, such as life, health, disability, and long-term care insurance, may be recommended as part of a financial plan. As such, licensed individuals are eligible to earn commission-based compensation for selling insurance products, including insurance products they sell to our clients. Insurance commissions earned by licensed individuals are separate from and in addition to our advisory fees. The sale of insurance products offered by Associated Persons is intended to complement our advisory services. However, this practice presents a conflict of interest because individuals providing investment advice on behalf of our firm who are insurance agents have an incentive to recommend insurance products to you for the purpose of generating commissions rather than recommending them based solely on your needs. We address this conflict of interest by recommending insurance products only where we, in good faith, believe that it is appropriate for the client’s particular needs and circumstances, and only after a full presentation of the recommended insurance product to our client. In addition, we explain the insurance underwriting process to our clients to illustrate how the insurer also reviews the client’s application and disclosures before the issuance of a resulting insuring agreement. Clients to whom the firm offers advisory services are informed that they are under no obligation to purchase insurance. Clients who choose to purchase insurance are under no obligation to use our licensed Associated Persons and may use any insurance brokerage firm and agent they choose. Item 6 – Performance-Based Fees and Side-By-Side Management Performance-based fees are based on a share of capital gains on or capital appreciation of the client’s assets. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. We do not accept  Pacific Capital Wealth Advisors, Inc. Form ADV Part 2A Brochure Page 11 performance-based fees or participate in side-by-side management. Our fees are calculated as described in the Fees and Compensation section above, and are not charged on the basis of a share of capital gains upon, or capital appreciation of, the funds in your advisory account(s). Item 7 – Types of Clients We generally offer investment advisory services to high net worth families, individuals, pension and profit- sharing plans and participants, trusts, estates, charitable organizations, corporations, and other business entities. We generally require a minimum of $25,000,000 of investable assets to establish a management account with us. We will count household assets for members of the same family to meet this minimum requirement. Additionally, we may waive this minimum requirement at our sole discretion based on individual circumstances. Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss We may use one or more of the following methods of analysis and/or investment strategies when providing investment advice to you: • Fundamental Analysis – Fundamental analysis involves analyzing individual companies and their industry groups, such as a company’s financial statements, details regarding the company’s product line, the experience and expertise of the company’s management, and the outlook for the company’s industry. The resulting data is used to measure the true value of the company’s stock compared to the current market value. The primary risk 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 a stock’s value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. • Technical Analysis – Technical analysis is a technique that relies on the assumption that current market data (such as charts of price, volume, and open interest) can help predict future market trends, at least in the short term. It assumes that market psychology influences trading and can predict when stocks will rise or fall. Technical trading models are mathematically driven based upon historical data and trends of domestic and foreign market trading activity, including various industry and sector trading statistics within such markets. Technical trading models, through mathematical algorithms, attempt to identify when markets are likely to increase or decrease and identify appropriate entry and exit points. The primary risk of technical trading models is that historical trends and past performance cannot predict future trends, and there is no assurance that the mathematical algorithms employed are designed properly, updated with new data, and can accurately predict future market, industry, and sector performance. • Cyclical Analysis – Cyclical analysis is similar to technical analysis in that it involves the analysis of market conditions at a macro (entire market/economy) or micro (company-specific) level, rather than the overall fundamental analysis of the health of the particular company. The primary risks with cyclical analysis are similar to those of technical analysis.  Pacific Capital Wealth Advisors, Inc. Form ADV Part 2A Brochure Page 12 • Charting – Charting involves the gathering and processing of price and volume pattern information for a particular security, sector, broad index, or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data are used to detect departures from expected performance and diversification and predict future price movements and trends. The primary risk 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. The investment advice provided along with the strategies suggested by Pacific Capital will vary depending on each client’s specific financial situation and goals. This brief statement does not disclose all of the risks and other significant aspects of investing in financial markets. In light of the risks, you should fully understand the nature of the contractual relationship(s) into which you are entering and the extent of your exposure to risk. Certain investing strategies may not be suitable for many members of the public. You should carefully consider whether the strategies employed would be appropriate for you in light of your experience, objectives, financial resources, and other relevant circumstances. We may use one or more of the following investment strategies when advising you on investments: • 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 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 the securities' short- term price fluctuations. Using a short-term purchase strategy generally assumes that we 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 time. • Trading – securities are sold within 30 days. The principal type of risk associated with trading is market risk. There can be no assurance that a specific investment will achieve its investment objectives, and past performance should not be seen as a guide to future returns. The value of investments and the income derived may fall as well as rise, and investors may not recoup the original amount invested. Other factors, such as changes in exchange control regulation, tax laws, withholding taxes, international, political, and economic developments, and government, economic, or monetary policies, may affect investments as well. Additionally, trading is speculative. Market movements are difficult to predict and are influenced by, among other things, government trade, fiscal, monetary, and exchange control programs and policies; changing supply and demand relationships; national and international political and economic events; changes in interest rates; and the inherent volatility of the marketplace. In addition, governments from time to time intervene, directly and by regulation, in certain markets, often with the intent to influence prices directly. The effects of governmental intervention may be  Pacific Capital Wealth Advisors, Inc. Form ADV Part 2A Brochure Page 13 particularly significant at certain times in the financial instrument markets, and such intervention (as well as other factors) may cause these markets to move rapidly. • Option Writing – an option is the right either to buy or sell a specified amount or value of a particular underlying investment instrument at a fixed price (i.e., the “exercise price”) by exercising the option before its specified expiration date. Options giving you the right to buy are called “call” options. Options giving you the right to sell are called “put” options. When trading options on behalf of a client, we generally use covered options. Covered options involve options trading when you own the underlying instrument on which the option is based. Investments in options contracts have the risk of losing value in a relatively short period. Option contracts are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock. This leverage can compound gains or losses. Transactions in options carry a high degree of risk. A relatively small market movement will have a proportionately larger impact, which may work for or against the investor. The placing of certain orders, which are intended to limit losses to certain amounts, may not be effective because market conditions may make it impossible to execute such orders. Selling ("writing" or "granting") an option generally entails considerably greater risk than purchasing options. Although the premium received by the seller is fixed, the seller may sustain a loss well in excess of that amount. The seller will also be exposed to the risk of the purchaser exercising the option, and the seller will be obliged either to settle the option in cash or to acquire or deliver the underlying investment. If the option is "covered" by the seller holding a corresponding position in the underlying investment or a future on another option, the risk may be reduced. • Margin Transactions – margin strategies allow an investor to purchase securities on credit and to borrow on securities already in their custodial account. Interest is charged on any borrowed funds for the period that the loan is outstanding. When you purchase securities, you may pay for the securities in full, or you may borrow part of the purchase price from your broker-dealer. If you intend to borrow funds in connection with your account, you will be required to open a margin account, which will be carried by the broker-dealer of your account. The securities purchased in such an account are the broker-dealer’s collateral for its loan to you. If the securities in a margin account decline in value, the value of the collateral supporting this loan also declines, and, as a result, a brokerage firm is required to take action, such as issue a margin call and/or sell securities or other assets in your accounts, in order to maintain a necessary level of equity in the account. It is important that you fully understand the risks involved in trading securities on margin, which are applicable to any margin account that you may maintain, including any margin Account that may be established as a part of our advisory services and held by your broker-dealer. These risks include the following: o You can lose more funds than you deposit in your margin account. o The broker-dealer can force the sale of securities or other assets in your account. o The broker-dealer can sell your securities or other assets without contacting you. o You may not be able to choose which securities or other assets in your margin account are liquidated or sold to meet a margin call. o The broker-dealer may move securities held in your cash account to your margin account and pledge the transferred securities. o You may not be entitled to an extension of time on a margin call. Investing in securities involves risk of loss that clients should be prepared to bear.  Pacific Capital Wealth Advisors, Inc. Form ADV Part 2A Brochure Page 14 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 will be profitable or equal any specific performance level(s). Past performance is not indicative of future results. Therefore, you should never assume that the future performance of any specific investment or investment strategy would be profitable. Investing in securities (including stocks, mutual funds, and bonds, etc.) involves risk of loss. Further, depending on the different types of investments, there may be varying degrees of risk. You should be prepared to bear investment loss, including loss of original principal. Because of the inherent risk of loss associated with investing, our firm is unable to represent, guarantee, or even imply that our services and methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate you from losses due to market corrections or declines. General Investment Risks All investments come with the risk of losing money. Investing involves substantial risks, including possible complete loss of principal plus other losses, and may not be suitable for many members of the public. Investments, unlike savings and checking accounts at a bank, are not insured by the government to protect against market losses. Different market instruments carry different types and degrees of risk, so you should familiarize yourself with the risks involved in the particular market instruments in which you intend to invest. • Loss of Value: There can be no assurance that a specific investment will achieve its investment objectives, and past performance should not be seen as a guide to future returns. The value of investments and the income derived may fall as well as rise, and investors may not recoup the original amount invested. Investments may also be affected by any changes in exchange control regulations, tax laws, withholding taxes, international, political, and economic developments, and governmental economic or monetary policies. • Interest Rate Risk: Fixed income securities and funds that invest in bonds and other fixed income securities may fall in value if interest rates change. Generally, the prices of debt securities rise when interest rates fall, and their prices fall when interest rates rise. Longer-term debt securities are usually more sensitive to interest rate changes. • Sector Risk: Funds that concentrate their portfolio in a specific sector may carry a higher degree of risk due to lower diversification and sector-specific risks. Because these investments are limited to a relatively narrow segment of the economy, the funds' investments are not as diversified as most funds. This means that these funds tend to be more volatile than other funds, and their portfolio values can increase or decrease more rapidly. The performance of each Fund may differ in direction and degree from that of the overall stock market. • Small Capitalization Risk: Funds that include smaller capitalization companies may involve greater risk than funds investing in larger, more established companies. For example, small capitalization companies may have limited product lines, markets, and financial or managerial resources. As a result, price movements in securities of smaller capitalization companies may be more volatile. Transaction costs in securities of smaller capitalization companies can be higher than those of larger capitalization companies, and there may be less liquidity. • Credit Risk: Investments in bonds and other fixed income securities are subject to the risk that the issuer(s) may not make required interest payments. An issuer suffering an adverse change in its  Pacific Capital Wealth Advisors, Inc. Form ADV Part 2A Brochure Page 15 financial condition could lower the credit quality of a security, leading to greater price volatility of the security. A lowering of the credit rating of a security may also offset the security's liquidity, making it more difficult to sell. Funds investing in lower-quality debt securities are more susceptible to these problems, and their value may be more volatile. • Company Risk: When investing in stock positions, there is always a certain level of company or industry-specific risk that is inherent in each investment. This is also referred to as unsystematic risk and can be reduced through appropriate diversification. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. For example, if a company’s employees go on strike or the company receives unfavorable media attention for its actions, the value of the company may be reduced. • Management Risk: Your investment with our firm varies with the success and failure of our investment strategies, research, analysis, and determination of portfolio securities. If our investment strategies do not produce the expected returns, the value of the investment will decrease. Recommendation of Particular Types of Securities As disclosed under the “Advisory Business” section in this Brochure, we provide advice on various types of securities, and we do not necessarily recommend one particular type of security over another since each client has different needs and different tolerances for risk. Each type of security has its own unique set of risks associated with it, and it would not be possible to list here all of the specific risks of every type of investment. Even within the same type of investment, risks can vary widely. However, in very general terms, the higher the anticipated return of an investment, the higher the risk of loss associated with it. Currently, we primarily invest client investment assets among various individual equity (stocks), debt (bonds), and fixed income securities, closed-end mutual funds, exchange traded funds (ETFs), and preferred stock on a discretionary basis, consistent with their designated objectives. Risks Associated with Specific Types of Securities • Equities (stocks): Common stocks are susceptible to general stock market fluctuations and to volatile increases and decreases in value as market confidence in and perceptions of their issuers change. If you held common stock, or common stock equivalents, of any given issuer, you would generally be exposed to greater risk than if you held preferred stocks and debt obligations of the issuer. • Fixed Income: When investing in bonds, there is the risk that the issuer will default on the bond and be unable to make payments. Further, individuals who depend on set amounts of periodically paid income face the risk that inflation will erode their spending power. Fixed-income investors receive set, regular payments that face the same inflation risk. • Municipal Securities: The value of municipal obligations can fluctuate over time. Value may be affected by adverse political, legislative, and tax changes. Financial developments affecting the municipal issuers affect the value as well. Because many municipal obligations are issued to finance similar projects by municipalities (e.g., housing, healthcare, water and sewer projects, etc.), conditions in the sector related to the project can affect the overall municipal market. Payment of municipal obligations may depend on an issuer’s general unrestricted revenues, revenue generated by a specific project, the operator of the project, or government appropriation or aid. There is a greater risk if investors can look only at the revenue generated by the project. In addition, municipal bonds generally are traded in the  Pacific Capital Wealth Advisors, Inc. Form ADV Part 2A Brochure Page 16 “over-the-counter” market among dealers and other large institutional investors. From time to time, liquidity in the municipal bond market (the ability to buy and sell bonds readily) may be reduced in response to overall economic conditions and credit tightening. • Investment Companies: Mutual funds and Exchange Traded Funds (“ETFs”) are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager who trades the fund's investments in accordance with the fund's investment objective. While mutual funds generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Investing in mutual funds and ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Investments in these securities are not guaranteed or insured by the FDIC or any other government agency. In addition, while some mutual funds are “no load” and charge no fee to buy into, or sell out of, other types of mutual funds do charge such fees, which can also reduce returns. • Preferred Securities: Preferred Securities have similar characteristics to bonds in that preferred securities are designed to make fixed payments based on a percentage of their par value and are senior to common stock. Like bonds, the market value of preferred securities is sensitive to changes in interest rates as well as changes in issuer credit quality. Preferred securities, however, are junior to bonds with regard to the distribution of corporate earnings and liquidation in the event of bankruptcy. Preferred securities that are in the form of preferred stock also differ from bonds in that dividends on preferred stock must be declared by the issuer’s board of directors, whereas interest payments on bonds generally do not require action by the issuer’s board of directors, and bondholders generally have protections that preferred stockholders do not have, such as indentures that are designed to guarantee payments – subject to the credit quality of the issuer – with terms and conditions for the benefit of bondholders. In contrast, preferred stocks generally pay dividends, not interest payments, which can be deferred or stopped in the event of credit stress without triggering bankruptcy or default. Another difference is that preferred dividends are paid from the issue’s after-tax profits, while bond interest is paid before taxes. • Alternatives: Non-traded REITs, business development companies, limited partnerships, and direct alternatives are subject to various risks such as liquidity and property devaluation based on adverse economic and real estate market conditions, and may not be suitable for all investors. A prospectus that discloses all risks, fees, and expenses may be obtained from your investment adviser representative. Read the prospectus carefully before investing. This is not a solicitation or offering which can only be made in conjunction with a copy of the prospectus. Investors considering an investment strategy utilizing alternative investments should understand that alternative investments are generally considered speculative in nature and involve a high degree of risk, particularly if concentrating investments in one or a few alternative investments. • Private Funds: Private investment funds are not registered with the Securities and Exchange Commission and may not be registered with any other regulatory authority. Accordingly, they are not subject to certain regulatory restrictions and oversight to which other issuers are subject. There may be  Pacific Capital Wealth Advisors, Inc. Form ADV Part 2A Brochure Page 17 little public information available about their investments and performance. Moreover, as sales of shares of private investment companies are generally restricted to certain qualified purchasers, it could be difficult for a client to sell its shares of a private investment company at an advantageous price and time. Since shares of private investment companies are not publicly traded, from time to time, it may be difficult to establish a fair value for the client’s investment in these companies. • Illiquid Securities: Illiquid securities involve the risk that investments may not be readily sold at the desired time or price. Securities that are illiquid, that are not publicly traded, and/or for which no market is currently available may be difficult to purchase or sell, which may impact the price or timing of a transaction. An inability to sell securities can adversely affect an account's value or prevent an account from taking advantage of other investment opportunities. Lack of liquidity may cause the value of investments to decline, and illiquid investments may also be difficult to value. A client may not be able to liquidate an investment in the event of an emergency or any other reason. Certain investment strategies used by our firm may invest in illiquid asset vehicles, such as private equity and real estate. Investment in an illiquid asset vehicle poses similar risks as direct investments in illiquid securities. In addition, investment in an illiquid asset vehicle will be subject to the terms and conditions of the illiquid asset vehicle’s investment policy and governing documents that often include provisions that may involve investor lock-in periods, mandatory capital calls, redemption restrictions, infrequent valuation of assets, etc. In addition, investments in illiquid securities or vehicles may normally involve investment in non-marketable securities where there is limited transparency. If obligated to sell an illiquid security prior to an expected maturity date, particularly with an infrastructure investment, they may not be able to realize fair value. Investments in illiquid securities or vehicles may include restrictions on withdrawal rights, and shares may not be freely transferable. Recommendation of Other Investment Advisers When a prospective client is not a fit for Pacific Capital, we may recommend an unaffiliated, third-party investment adviser (TPIA). Please see Item 4 above for more information regarding the recommendation of TPIAs, the fees we receive, and associated conflicts of interest. Prospects are not required to utilize the services of any recommended TPIA. Please see the recommended TPIA’s Form ADV Part 2 or equivalent disclosure brochure for information on their specific methods of analysis, investment strategies, and associated risks involved. Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of us or of the integrity of our management. Neither we nor our management personnel have a history of material legal or disciplinary events. Item 10 – Other Financial Industry Activities or Affiliations No one associated with Pacific Capital is currently registered with a broker-dealer. Additionally, neither Pacific Capital nor its representatives is registered as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor.  Pacific Capital Wealth Advisors, Inc. Form ADV Part 2A Brochure Page 18 Insurance Activities Certain Executive Officers and other Associated Persons of our firm are licensed as independent insurance agents. Insurance products, such as life, health, disability, and long-term care insurance, may be recommended as part of a financial plan. As such, licensed individuals are eligible to earn commission-based compensation for selling insurance products, including insurance products they sell to our clients. Insurance commissions earned by licensed individuals are separate from and in addition to our advisory fees. The sale of insurance products offered by Associated Persons is intended to complement our advisory services. However, this practice presents a conflict of interest because individuals providing investment advice on behalf of our firm who are insurance agents have an incentive to recommend insurance products to you for the purpose of generating commissions rather than recommending them based solely on your needs. We address this conflict of interest by recommending insurance products only where we, in good faith, believe that it is appropriate for the client’s particular needs and circumstances, and only after a full presentation of the recommended insurance product to our client. In addition, we explain the insurance underwriting process to our clients to illustrate how the insurer also reviews the client’s application and disclosures before the issuance of a resulting insuring agreement. Clients to whom the firm offers advisory services are informed that they are under no obligation to purchase insurance. Clients who choose to purchase insurance are under no obligation to use our licensed Associated Persons and may use any insurance brokerage firm and agent they choose. Recommendation of Other Investment Advisors When a prospective client is not a fit for Pacific Capital, we may recommend an unaffiliated, third-party investment adviser (TPIA). Please see Item 4 above for more information regarding the referral arrangements we have with recommended TPIAs, including the financial incentive we have when making recommendations where we receive a referral fee. Prospects are not required to utilize the services of any recommended TPIA. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Description of Our Code of Ethics Pacific Capital has adopted a Code of Ethics (the “Code”) to address investment advisory conduct. The Code focuses primarily on fiduciary duty, personal securities transactions, insider trading, gifts, and conflicts of interest. The Code includes Pacific Capital’s policies and procedures developed to protect clients’ interests in relation to the following topics:     The duty at all times to place the interests of clients first; The requirement that all personal securities transactions be conducted in such a manner as to be consistent with the Code; The responsibility to avoid any actual or potential conflict of interest or misuse of an employee’s position of trust and responsibility; The fiduciary principle that information concerning the identity of security holdings and the financial circumstances of clients is confidential; and The principle that independence in the investment decision-making process is paramount.  Participation or Interest in Client Transactions and Personal Trading Practices From time to time, we or our Associated Person may buy or sell the same securities at the same time or in proximity to transactions in client accounts. Generally, personal trades will be “last in” and “last out” for the trading day. Front running (trading shortly ahead of clients) is prohibited.  Pacific Capital Wealth Advisors, Inc. Form ADV Part 2A Brochure Page 19 When possible, we may combine orders for firm or Associated Persons with client orders ("block trading") in order to receive an average share price and to ensure that personal transactions are not favored over client transactions. Please refer to the "Brokerage Practices" section in this brochure for information on our block trading practices. At times, Pacific Capital and/or its Associated Persons may buy or sell a specific security for their own account based on personal investment considerations, which may not be suitable for client accounts. In any case, personal securities transactions are actively monitored for compliance with our Code of Ethics and to ensure that we adhere to our fiduciary responsibilities to our clients. A copy of Pacific Capital’s Code of Ethics is available upon request to our firm at (844) 777-8777 or at aurielle@pacificcapital.com. Item 12 – Brokerage Practices Our firm will not maintain physical custody of your assets that we manage, although we are deemed to have custody of your assets if you give us authority to withdraw advisory fees from your account (see Item 15— Custody, below). Your assets must be maintained in an account at a “qualified custodian,” generally a broker- dealer, bank, or trust company, for example. We routinely request that our clients use Charles Schwab & Co., Inc. (“Schwab”), a registered broker-dealer, member SIPC, as the qualified custodian. We are independently owned and operated and are not affiliated with Schwab. Schwab will hold your assets in a brokerage account and buy and sell securities when you or we instruct it to. While we recommend that you use Schwab as custodian/broker, you will decide whether to do so and will open your account with Schwab by entering into an account Agreement directly with them. Conflicts of interest associated with this arrangement are described below, as well as in Item 14 (client Referrals and Other Compensation). You should consider these conflicts of interest when selecting your custodian. We do not open the account for you, although we may assist you in doing so. Not all advisors require their clients to use a particular broker-dealer or other custodian selected by our firm. Even though your account is maintained at Schwab, and we anticipate that most trades will be executed through Schwab, we can still use other brokers to execute trades for your account as described below (see “Your Brokerage and Custody Costs”). How We Select Brokers/Custodians When considering whether the terms that Schwab provides are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: • • • Combination of transaction execution services and asset custody services (generally without a separate fee for custody) Capability to execute, clear, and settle trades (buy and sell securities for your account) Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payments, etc.) • Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds (ETFs), etc.) • Availability of investment research and tools that assist us in making investment decisions  Pacific Capital Wealth Advisors, Inc. Form ADV Part 2A Brochure Page 20 • Quality of services • Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices Prior service to our clients and us Services delivered or paid for by Schwab • Reputation, financial strength, security, and stability • • • Availability of other products and services that benefit us, as discussed below Your Brokerage and Custody Costs For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. Certain trades (for example, certain mutual funds and ETFs) do not incur Schwab commissions or transaction fees. Schwab is also compensated by earning interest on the uninvested cash in your account in Schwab’s Cash Features Program. In addition to transaction fees, Schwab charges you a flat dollar amount as a “prime broker” or “trade away” fee for each trade that we have executed by a different broker-dealer, but where the securities bought or the funds from the securities sold are deposited (settled) into your Schwab account. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. Because of this, in order to minimize your trading costs, we will have Schwab execute most trades for your account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through Schwab, we have determined that having Schwab execute most trades is consistent with our duty to seek “best execution” of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see “How We Select Brokers/Custodians”). By using another broker or dealer, you may pay lower transaction costs. Research and Other Soft Dollar Benefits Although the following products and services are not purchased with “soft dollar” credits, we will receive certain economic benefits (soft dollar benefits) from Schwab in the form of access to Schwab’s institutional brokerage and support services at no additional cost or at a discounted cost. Below is a detailed description of Schwab’s support services: Products and Services Available to Us from Schwab Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like ours. They provide our clients and us with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to Schwab retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. Schwab also offers various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis (we don’t have to request them) and at no charge to us. Services that Benefit You: Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some that we might not otherwise have access to, or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account.  Pacific Capital Wealth Advisors, Inc. Form ADV Part 2A Brochure Page 21 Services that Do Not Directly Benefit You: Schwab also makes available to us other products and services that benefit us but do not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts and operating our firm. They include investment research, both Schwab’s own and that of third parties. We use this research to service all or a substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: provide access to client account data (such as duplicate trade confirmations and account statements) facilitate trade execution and allocate aggregated trade orders for multiple client accounts provide pricing and other market data facilitate payment of our fees from our clients’ accounts assist with back-office functions, recordkeeping, and client reporting • • • • • Services that Generally Benefit Only Us: Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: Educational conferences and events Consulting on technology and business needs Consulting on legal and compliance-related needs Publications and conferences on practice management and business succession • • • • • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support • Recruiting and custodial search consulting Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab also discounts or waives its fees for some of these services or pays all or a part of a third party’s fees. Schwab also provides us with other benefits, such as occasional business entertainment for our personnel. If you did not maintain your account with Schwab, we would be required to pay for those services from our own resources. Our firm understands its duty for best execution and considers all factors in making recommendations to clients. These research services may be useful in servicing all clients and may not be used in connection with any particular account that may have paid compensation to the firm providing such services. While we may not always obtain the lowest commission rate, we believe the rate is reasonable in relation to the value of the brokerage and research services provided. Our Interest in Schwab’s Services The availability of these services from Schwab benefits us because we do not have to produce or purchase them. We don’t have to pay for Schwab’s services. Schwab has also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on our behalf once the value of our clients’ assets in accounts at Schwab reaches certain thresholds. The fact that we receive these benefits from Schwab is an incentive for us to recommend the use of Schwab rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. We believe, however, that taken in the aggregate, our recommendation of Schwab as custodian and broker is in the best  Pacific Capital Wealth Advisors, Inc. Form ADV Part 2A Brochure Page 22 interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services (see “How We Select Brokers/Custodians”) and not by Schwab’s services that benefit only us. 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. Directed Brokerage Pacific Capital does not accept directed brokerage arrangements. As such, all clients will be required to use the services of Schwab. Not all advisers require their clients to direct brokerage to a particular broker- dealer/custodian. By directing brokerage, we may be unable to always achieve the most favorable execution of client transactions, which may result in higher commissions and/or trading costs than those that may be available elsewhere. Order Aggregation (Block Trades) We may “bunch” buy or sell orders for two or more clients into a single large order and place the bunched order with a single broker or dealer for execution (this practice is commonly referred to as “block trading”). We are not obligated to place all transactions on a “bunched” basis. When determining whether to “bunch” orders, we decide what course of action is likely to be fair and in the best interests of the relevant accounts on an overall basis. That is, we seek to avoid putting any client account at an advantage or disadvantage compared to our other client accounts that are buying or selling the same security. Block trading is permitted where the following conditions are met. Orders of two or more accounts may be bunched only if we have determined, on an individual basis, that the securities order is: In the best interests of each client participating in the order; 1. 2. Consistent with our duty to obtain best execution, and 3. Consistent with the terms of the Investment Advisory Agreement of each participating client. When conducting a block trade, we will determine the accounts that will participate and the specific allocations in advance of the transaction. If the entire order is filled, each participating account will receive its portion of the allocation specified on the trade ticket. All allocations are made before the close of business on the trade date. Each account participating in the transaction will receive the weighted average price of the security and will incur a pro-rata share of the transaction cost. If part of the order is unfilled, the allocation is done on a pro-rata basis. The books and records of Pacific Capital separately reflect, for each participating account, the securities held by, purchased, and sold for that account. Accounts owned by our firm or persons associated with our firm may participate in block trading with client accounts; however, they will not be given preferential treatment. In the unlikely event of a partial fill, shares will be allocated to participating client accounts before any participating personal accounts. Item 13 – Review of Accounts Account Reviews Pacific Capital monitors client account holdings on a continuous basis. All advisory accounts are reviewed at least quarterly together by our investment advisor representatives, Chad Willardson, President, and Morgan Fippinger, Director of Investment Strategy. Other factors may determine a need for more frequent internal  Pacific Capital Wealth Advisors, Inc. Form ADV Part 2A Brochure Page 23 account reviews, such as contributions and withdrawals of cash from an account, significant geopolitical events, or upon client request. Advisory clients receive trade confirmations of each transaction from the custodian of their assets. Clients also receive statements of account activity at least quarterly, or any month there is activity in their account. These are in the form of brokerage account statements. Pacific Capital does not provide regular written reports in addition to brokerage account statements. A financial plan is a snapshot in time and is delivered to the client upon completion of the Financial Life Inspection®. Ongoing reviews are conducted for clients who engage in our investment management services. Plan updates are provided in writing. Item 14 – Client Referrals and Other Compensation Client Referrals We do not pay for client referrals. However, we receive compensation when we make a referral to an unaffiliated, third-party investment adviser (TPIA) with whom we have a referral compensation agreement. Please see Item 4 above for more information regarding the referral arrangements we have with recommended TPIAs, including the financial incentive to recommend TPIAs with whom we have more favorable compensation arrangements. Prospects are not required to utilize the services of any recommended TPIA. Custodial Benefits As described in Item 12 above, we receive economic benefits from our custodial broker-dealer, Schwab, in the form of support products and services they make available to us and other independent investment advisors whose clients maintain their accounts at these custodial broker-dealers. The availability of custodial products and services is not dependent upon or based on the specific investment advice we provide our clients, such as buying or selling specific securities or specific types of securities for our clients. The products and services provided by the custodial broker-dealer, how they benefit us, and the related conflicts of interest are described above (see Item 12 – Brokerage Practices). Item 15 – Custody We do not have physical custody of any of your funds and/or securities. Your funds and securities will be held with a bank, broker-dealer, or other independent, qualified custodian, such as Schwab. Pursuant to your written authorization, as paying agent for our firm, your independent, qualified custodian will directly debit your account(s) for the payment of our advisory fees. The ability for us to calculate the advisory fee and send an invoice to the custodian with the amount of our fee to be deducted from your account causes our firm to exercise limited custody over your funds or securities for the purposes of debiting our advisory fees. Additionally, we are deemed to have custody in certain situations where we accept standing letters of authorization from clients to transfer assets to third parties. In all cases, we maintain safeguards in accordance with regulatory requirements regarding the custody of client assets. You will receive account statements from the independent, qualified custodian(s) holding your funds and securities at least quarterly. The account statements from your custodian(s) will indicate the amount of our advisory fees deducted from your account(s) each billing period. You should carefully review account  Pacific Capital Wealth Advisors, Inc. Form ADV Part 2A Brochure Page 24 statements for accuracy. If you have questions regarding your account or if you did not receive a statement from your custodian, please contact our firm at (844) 777-8777 or at aurielle@pacificcapital.com. Item 16 – Investment Discretion Pacific Capital requires discretionary authority to manage securities accounts on behalf of clients. This means that Pacific Capital has the authority to determine the securities to be bought or sold and the amount of the securities to be bought or sold for the client's account(s) without obtaining specific client consent before each transaction. The client will authorize Pacific Capital to take discretionary authority as stated within the Investment Advisory Agreement. Pacific Capital allows clients to place reasonable restrictions, as outlined in the client’s Investment Strategy Guide or similar document. These restrictions must be provided to Pacific Capital in writing. The client approves the custodian to be used and the commission rates paid to the custodian in an account agreement directly with the account custodian. Pacific Capital does not receive any portion of the transaction fees or commissions paid by the client to the custodian. Item 17 – Voting Client Securities Pacific Capital does not vote proxies. It is the client's responsibility to vote proxies. Clients will receive proxy materials directly from the custodian. Item 18 – Financial Information We are required in this Item to provide you with certain financial information or disclosures about Pacific Capital’s financial condition. Pacific Capital does not require prepayment of over $1,200, six or more months in advance. Additionally, Pacific Capital has no financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients, and it has not been the subject of a bankruptcy proceeding.